Christakis v. Jeanne D'Arc Credit Union

The issue on appeal is whether judicial liens on real property remain valid after the owner of the property receives a discharge under Chapter 7 of the Bankruptcy Code. We conclude that the judicial liens survive the discharge where, as here, the Bankruptcy Court judge did not avoid them. 2

Background. The plaintiff, Pagona Christakis, filed a complaint in the Land Court to remove judicial liens that had attached to real property she owned in Billerica after three creditors obtained final judgments against her. Only one creditor defendant, Jeanne D’Arc Credit Union (credit union), filed an…