Lynch v. Jackson

853 F.3d 116 (2017)

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Lynch v. Jackson

United States Court of Appeals for the Fourth Circuit
853 F.3d 116 (2017)

Facts

Gabriel and Monte Jackson (plaintiffs) filed a chapter 7 bankruptcy petition. Because the Jacksons earned more than the median income for a family of the same size in their state, they had to complete the Form 22A means test. Form 22A instructed debtors to use the Internal Revenue Service (IRS) National and Local Standards for certain expense amounts, regardless of the debtor’s actual expenses. The Jacksons completed the form based on those instructions and used the local standard expense amounts, even though their actual expenses were lower. Bankruptcy administrator Marjorie Lynch (defendant) moved to dismiss the Jacksons’ bankruptcy petition, arguing that the petition abused the provisions of chapter 7. Lynch argued that the instructions on Form 22A were incorrect and that in completing the means-test calculation, debtors should use the lesser of the debtor’s actual expenses or the applicable standard expense amount. The bankruptcy court denied the motion to dismiss, concluding that the Jacksons’ use of the local standard amounts complied with the plain language of 11 U.S.C. § 707(b)(2)(A)(ii)(I). That section provides that the monthly expenses to deduct from the debtor’s monthly income “shall be the debtor’s applicable monthly expense amounts specified under the National Standards and Local Standards, and the debtor’s actual monthly expenses for the categories specified as Other Necessary Expenses . . . .” Lynch appealed, and the United States Court of Appeals for the Fourth Circuit accepted the case to consider whether a debtor could use the full national and local standard amount for expenses even if the debtor’s actual expenses were less than the standard amount.

Rule of Law

Issue

Holding and Reasoning (Thacker, J.)

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