HSBC Bank USA, National Ass'n v. Blendheim (In Re Blendheim)

OPINION

BYBEE, Circuit Judge:

Robert and Darlene Blendheim are colloquially known as “Chapter 20” debtors. Like many others who sought bankruptcy relief during the housing crisis, they took advantage of the bankruptcy tools available under Chapter 7 and then filed for Chapter 13 relief. One of the tools available in a Chapter 13 reorganization is lien voidance, or “lien stripping.” Ordinarily, the Bankruptcy Code permits Chapter 13 debtors to void or modify certain creditor liens on the debtor’s property, permanently barring the creditor from foreclosing on that property. However, a 2005…