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assessment was against the debtor personally, so its validity did not turn on whether the property of the estate had revested in him at the time.)
In re Pratt, 462 F.3d 14 (1st Cir. Sept. 1, 2006) (Secured creditor violated debtor's discharge injunction pursuant to § 524(a) by exercising its state law right to refuse to release lien on motor vehicle which had been surrendered by the debtor pursuant to § 521(a)(2)(A) but not retrieved by the creditor. The reason for the lien no longer existed because the vehicle had no value, and the creditor's refusal to either retrieve the vehicle or release the lien so that it could be junked by the debtor, amounted to coercion in violation of § 524(c).)
U.S. Commodity Futures Trading Commission v. NRG Energy, Inc., 457 F.3d 776 (8th Cir. Aug. 4, 2006) (District Court of Minnesota had jurisdiction to hear the U.S. Commodity Futures Trading Commission's enforcement action to enjoin the debtor from inaccurately reporting market information, even though the Commission's prepetition claim had been disallowed and the debtor's Chapter 11 plan purported to limit jurisdiction of future litigation against the debtor to the Bankruptcy Court for the Southern District of New York. Neither bankruptcy order applied to an action to enjoin prospective acts of the debtor.)
Hazelquist v. Guchi Moochie Tackle Co., Inc., 437 F.3d 1178 (Fed. Cir. Feb. 9, 2006) (Discharge injunction under § 524(a)(2) does not bar continuation of prepetition civil action to the extent it seeks to recover for debtor's post-discharge patent infringement. Plaintiff initiated action pre-petition alleging defendant infringed on plaintiff's patent. Defendant filed Chapter 7 petition and obtained discharge. District Court then dismissed the pre-petition action based on the discharge despite plaintiff's objection that defendant's patent infringement continued after discharge. Court of Appeals reversed because each act of infringement gives rise to a separate cause of action. Just as § 362 only stays actions that arose or could have been commenced pre-petition, § 524(a)(2) only operates as a continuing injunction of debts that arose before discharge.)
524(d) Reaffirmation
McCready v. eBay, Inc., 453 F.3d 882 (7th Cir. July 10, 2006) (Debtor/Plaintiff failed to state a claim for rescission pursuant to § 521 and § 524, because the debtor's allegation that his reaffirmation agreement was invalid did not allege a injury or request a remedy.)
525 Discrimination
Ayes v. United States Dept. of Veterans Affairs, 473 F.3d 104 (4th Cir. Dec. 27, 2006) (Veterans Administration did not violate § 525(a) when it refused to guarantee home loans of veterans who had previously obtained bankruptcy discharges. The veteran guaranty entitlement is not a license, permit, charter, franchise or other similar grant covered by the non-discrimination provisions of § 525(a). The governmental authorizations covered by § 525(a) are those that
