Case Summary:
Land contract vendors objected to confirmation of the Debtors’ Chapter 13 plan proposing to cure a default after the redemption date set in a judgment of strict foreclosure. Under Wisconsin law, equitable title remained with the Debtors because the state court had not entered an order confirming the default after the expiration of the redemption period. Section 1322’s more specific cure provision governed the Debtors’ ability to cure, not the general provisions of section 108(b) extending a non-bankruptcy deadline for curing a default. The Debtors could cure the default within a “reasonable time” in their plan under section 1322(b)(5).

Statute/Rule References:
11 U.S.C. § 1322(b)(5) -- Provide for Curing of Default

Key Terms:
Confirmation - Chapter 13
Cure in Chapter 13 Plan
Plan Confirmation
Specificity of Statute