September 24, 2018 Makewhole Premium Disallowed When the Debt Had Been Accelerated Judge Flatley avoids taking sides in the Second/Third Circuit split. 4th Circuit , West Virginia , West Virginia Northern District , February 6, 2018 Ok to Bifurcate the Lien on an Auto Used by the Debtor’s Non-Filing Partner Congress created a loophole in the hanging paragraph in Section 1325(a). 4th Circuit , West Virginia , West Virginia Northern District ,