Rushing v. Green Tree Servicing, LLC (In Re Rushing)
This memorandum of decision addresses motions to dismiss filed by defendants Green Tree Servicing, LLC and John Patrick Herr against plaintiffs Ira Glen Rushing (Debtor) and Jacqueline Y. Berry (non-debtor spouse). The plaintiffs alleged automatic stay violations under 11 U.S.C. § 362(k) stemming from the defendants' actions during Rushing's Chapter 13 bankruptcy. The court denied the motions to dismiss concerning Rushing's claims, ruling that automatic stay violation claims are not subject to arbitration or state limitations periods. However, the court granted the motions to dismiss regarding Berry's claims, determining that as a non-debtor spouse, she lacks standing to pursue a remedy under § 362(k) because her grievances are not within the zone of interests protected by the statute.