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In re Thompson

United States Bankruptcy Court for the Western District of Virginia
2018 WL 2717044 (2018)


Eric Thompson (debtor) financed a car through OneMain Financial (creditor) on August 30, 2016. Thompson signed an application requesting transfer of a lien to OneMain, and the Department of Motor Vehicles (DMV) date-stamped the lien application “Received” on September 2, 2016. In addition, a DealerTrack summary showed the title issued electronically on August 30, 2016, and the transfer of lien information received as of September 28, 2016. In 2018, Thompson filed for bankruptcy. Shortly afterward, OneMain filed a proof of claim in Thompson’s bankruptcy proceeding, with the security agreement signed by Thompson and a statement from DealerTrack noting the lien issuance and filing dates. The DMV issued a paper title certificate stamped “Original” showing the lien a month later, without any further action on OneMain’s part. Thompson objected to OneMain’s claim, arguing it perfected its lien after he filed for bankruptcy when the DMV printed the paper title certificate, in violation of the automatic stay, meaning OneMain had no secured claim.

Rule of Law


Holding and Reasoning (Connelly, J.)

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