Case Summary:
Debtors William and Lisa Mossuto sought to estimate the claim of creditor CRS Properties, LLC. CRS obtained a prepetition foreclosure judgment in state court. Debtors appealed the judgment and filed their Chapter 13 petition before the redemption period expired. In their bankruptcy case, Debtors objected to CRS’s claim and requested this Court estimate the claim for the purposes of plan confirmation and a pending motion for relief from the automatic stay. In response, CRS pointed to the state court judgment and requested this Court to adopt the value of the judgment as the correct and allowed amount of its claim. This Court agreed with CRS. The first issue was whether Rooker-Feldman barred this Court from reviewing the judgment, which this Court found it didn’t since the judgment had been appealed. But secondly, the doctrine of claim preclusion obliged this Court to give preclusive effect to the foreclosure judgment since there was an identity of the parties, an identity of the claims, and the judgment constituted a final judgment on the merits. Further, although Debtors argued that the value of their property was lower than the filed secured claim of CRS, they offered no evidence in support of their alleged valuation. Thus, the Court allowed CRS’s secured claim in the amount filed.

Statute References:
11 U.S.C. § 502 -- Allowance of claims or interests
28 U.S.C. § 1738 -- State and Territorial statutes and judicial proceedings; full faith and credit

Key Terms:
Claim Estimation
Claim Preclusion
Rooker-Feldman
Valuation