Three Circuits Now Say ‘13’ Trustees Aren’t Paid if Dismissal Precedes Confirmation

The same question has been sub judice in the Second Circuit for 15 months. Is the Second Circuit on the cusp of making a circuit split?

Seventh Circuit to Rule on Paying ‘13’ Trustees if Dismissal Precedes Confirmation

Within the next year, four circuits will have ruled on a split where some lower courts pay chapter 13 trustees and others don’t when dismissal precedes confirmation.