In Re Rowe’s Empirical Analysis

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Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Because the plan may not extend beyond five years, this section will encompass short term mortgages, long term mortgages on which the debtor has nearly completed payments, and mortgages with balloon payments. Congress obviously believed that debtors with such mortgages needed additional protection. Short-term mortgages and balloon payment mortgages often have high rates or terms that are particularly unfavorable, which Congress has deemed deserving of close scrutiny. And debtors nearing the end of a long-term mortgage often have large amounts of equity that could be lost in a foreclosure.”

   1 later decision quote this exact passage · from the concurrence
   e.g. In re Goione

2. “(c) Notwithstanding subsection (b)(2) and applicable nonbankruptcy law- [[Image here]] (2) in a case in which the last payment on the original payment schedule for a claim secured only by a security interest in real property that is the debt- or’s principal residence is due before the date on which the final payment under the plan is due, the plan may provide for the payment of the claim as modified pursuant to section 1325(a)(5) of this title.”

   1 later decision quote this exact passage
   e.g. In re Holmes

3. “the 'last payment' language of section 1322(c)(2) refers to the date of the last payment on the original note rather than the date the accelerated debt is due.”

   1 later decision quote this exact passage · from the concurrence
   e.g. In re Goione