In re Jaffe

MEMORANDUM OPINION

A. Benjamin Goldgar, United States Bankruptcy Judge

This case poses a frequently-posed issue—how a judgment should be treated in bankruptcy when the judgment is recorded against a debtor’s property held in a tenancy by the entirety. To what extent does the judgment creditor have a lien, and can the debtor avoid that lien under section 522(f) of the Bankruptcy Code, 11 U.S.C. § 522(f)? Here, debtor Scott N. Jaffe seeks to avoid a judgment lien that Laverne Williams says she holds against the residence Jaffe and his wife owned on the petition date as tenants by the entirety.…