Martha Irene Weed v. Rosa Beatrice Washington

Appellant Rosa Beatrice. Washington, pro se, appeals the district court’s order reversing the bankruptcy court’s ruling. The bankruptcy court allowed Washington to avoid her attorney’s hen on Washington’s homestead property pursuant to § 522(f)(1) of the Bankruptcy Code, but the district court held that the lien was not a “judicial lien” avoidable under § 522(f)(1). 11 U.S.C. § 522(f)(1). After review, we affirm the decision of the district court in part and vacate and remand in part.

I. BACKGROUND

On December 9, 1993, Washington entered into a retainer agreement with attorney Martha Irene Weed…