On Nov. 9, the U.S. Court of Appeals for the Eleventh Circuit issued its opinion in Lindsey Jones v. CitiMortgage, et al., concluding that district courts lack jurisdiction to rule on alleged violations of bankruptcy discharge injunctions.
Even though the case dealt with a Georgia foreclosure of real estate, the decision applies to Florida bankruptcy proceedings as well. By affirmatively determining that bankruptcy courts alone “possess the power to enforce compliance” with discharge injunctions (as opposed to district courts or state courts), the Eleventh Circuit reinforced its previous decisions in In re McLean, in 2015, and Alderwoods Group v. Garcia in 2012.
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