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Cohen v. Third Coast Bank (In re Cohen)

UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT
Apr 8, 2015
599 F. App'x 192 (5th Cir. 2015)

Summary

affirming the district court's decision that borrowing base certificates were not statements respecting the borrower's financial condition because they did not list the borrower's other assets, such as equipment or cash, and they failed to provide any information about the borrower's liabilities

Summary of this case from Fulton, N.A. v. Robbins (In re Robbins)

Opinion

No. 14-40760

04-08-2015

In the Matter of: HADLEY COHEN; MELINDA K. COHEN, Debtors HADLEY COHEN, Appellant v. THIRD COAST BANK, SSB, Appellee


Appeal from the United States District Court for the Eastern District of Texas
USDC No. 1:13-CV-610
Before REAVLEY, SMITH, and GRAVES, Circuit Judges. PER CURIAM:

Pursuant to 5TH CIR. R. 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5TH CIR. R. 47.5.4.

The judgment of the district court is affirmed for the following reasons.

Appellant concedes that his representations to the bank of his assets and liabilities were false. The bankruptcy court trying the case found that the bank justifiably relied on the false representation to its damages, as found.

Plaintiff argues that the finding of reliance was clear error because the bank had knowledge of the risk of accepting the representations without conducting an investigation that would reveal the falsehood. This court will not impose on banking officials this requirement. Under all of these circumstances and the customary practice of lending institutions, it is necessary for them to be able to accept what Plaintiff signed as true. The finding stands.

The Plaintiff also seizes on the language in the statute § 523(a)(2)(A), excluding discharge for "a statement respecting the debtor's or an insider's financial condition." Because the borrowing base certificates are statements of financial condition, the argument is that for Plaintiff to be discharged the court has to go to the following statutory requirement and require a finding of reasonable reliance. He misreads Bandi v. Becanel where this court distinguished statements that are only about general conditions of the borrower from specific falsifications on the ability to repay the lender, misstatements of inventory and denial of other secured creditors with priority - as was true here - that are not dischargeable.

AFFIRMED.


Summaries of

Cohen v. Third Coast Bank (In re Cohen)

UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT
Apr 8, 2015
599 F. App'x 192 (5th Cir. 2015)

affirming the district court's decision that borrowing base certificates were not statements respecting the borrower's financial condition because they did not list the borrower's other assets, such as equipment or cash, and they failed to provide any information about the borrower's liabilities

Summary of this case from Fulton, N.A. v. Robbins (In re Robbins)
Case details for

Cohen v. Third Coast Bank (In re Cohen)

Case Details

Full title:In the Matter of: HADLEY COHEN; MELINDA K. COHEN, Debtors HADLEY COHEN…

Court:UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

Date published: Apr 8, 2015

Citations

599 F. App'x 192 (5th Cir. 2015)

Citing Cases

Haler v. Boyington Capital Grp., LLC

See also Cohen v. Third Coast Bank, SSB, No. 1:13-CV-610, 2014 WL 2729608, at *9 (E.D. Tex. June 16, 2014),…

Fulton, N.A. v. Robbins (In re Robbins)

Under the strict interpretation, borrowing base certificates do not qualify as written statements about a…