Graziani v. Randolph

CONCURRING OPINION BY

KLEIN, J.:

¶ 1 Because I believe that certain issues raised in the prior incarnation of this appeal remain unclear and because such issues may arise in other actions, I write separately. The issues are the confusion over whether certain actions taken during the bankruptcy are void or voidable and the need for specific proof of intent to ratify those actions.

Actions taken against a debtor during the pendency of bankruptcy are void.

¶ 2 Many courts, including our own, are uncertain as to whether actions taken against a debtor during the pendency of a bankruptcy are void or…