Jurisdiction: Bankr. D. Colo.
Date: 11/18/2025
Holding: The court denied Keirton’s motion to reconsider and refused to vacate the prior order reinstating the debtor’s case. The court held that Keirton received proper notice, waived any objections by failing to respond, and that reinstatement was justified under Rule 60(b) and practical considerations.
NACBA Case Law Updates are an exclusive members-only benefit designed to keep you informed on the latest developments impacting consumer bankruptcy practice. To access all recent monthly updates, simply sign in to your NACBA account. We also extend our appreciation to Jim Haller, Executive Director of NCBRC, who authors these valuable updates for our members.
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Time’s almost up!
Register for NACBA’s 34th Annual Convention by November 30 to be entered into our raffle for two free nights at the Sheraton Boston Hotel during the convention, April 9–12, 2026.
If you’ve already registered, you’re automatically entered—no extra steps needed.
Join your fellow consumer bankruptcy professionals in Boston for unmatched CLE, networking, and insight—and maybe enjoy part of your stay on us!
Register by November 30!
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Webinar Title: Consumer Laws Trends in Bankruptcy Cases
When: Thursday, December 11
Time: 2:00–3:00 PM ET
Bankruptcy practices are loaded with potential consumer claims-you just have to know where to look. Litigation attorneys can partner with bankruptcy practitioners to handle consumer claims. Bankruptcy attorneys can partner with litigation attorneys so that they have an experienced litigator to whom they can refer to potential consumer claims. In short, this situation is a win/win/win for the client, the bankruptcy attorney and the litigation attorney.
What You’ll Learn:
1. What are common consumer claims found in bankruptcy cases
2. Where to find consumer claims in bankruptcy cases
3. How to set up a referral or co-counseling relationship
Speakers:
-Cliff Carlson – Sole practitioner focusing on consumer debt and consumer rights, handling FDCPA and FCRA cases across GA, OH, TX, and AL.
-John Steinkamp – Indianapolis attorney specializing in consumer bankruptcy and litigation, with 650+ FDCPA cases and extensive trial experience.
*Special Benefit for NACBA Members: As a co-sponsor of this event, NACBA members can attend the live webinar at no cost!
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October 10-12, 2026
Wailea Beach Marriott
NACBA members, mark your calendars for our 2026 Members-Only Workshop in beautiful Maui! Stay tuned for more details on programming, registration, and travel information—this is an event you won’t want to miss.
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In Langston v. Dallas Commodity Company, No. 24-10883 (5th Cir. Nov. 17, 2025), the U.S. Court of Appeals for the Fifth Circuit addressed a recurring challenge in consumer bankruptcy practice: what happens when a trustee fails to properly continue a Section 341 meeting of creditors under Federal Rule of Bankruptcy Procedure 2003(e)? While the court affirmed that such procedural failures do not automatically trigger a bright-line rule concluding the meeting, it established important precedent distinguishing between cases where another meeting is actually held versus cases where no further meeting occurs. Most significantly for practitioners, the decision underscores how easily debtors can waive the protections of the 30-day deadline to object to exemptions under Rule 4003(b)(1)—and provides a roadmap for avoiding such waivers.
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The holiday season is coming fast—and smart NACBA shippers know that early planning is key. Whether you're sending gifts to loved ones or fulfilling customer orders, UPS offers reliable delivery, flexible tools, and protection options to help you ship with confidence. Start by reviewing the 2025 UPS Year-End Holiday Schedule to avoid delays and stay ahead of key shipping deadlines.
Discover the advantages our UPS savings program has to offer, just like many of our satisfied members. Save 65% on domestic UPS® Next Day and 42% on UPS® Ground. No code needed! Take advantage of incredible savings today by signing up for a new account or enrolling your existing one to access exclusive new member savings incentives!
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The Consumer Bankruptcy Journal (formerly NACBA Now) is the official publication of the National Association of Consumer Bankruptcy Attorneys.
Readers include attorneys, judges, paralegals, legal assistants, law students, Bar Associations around the country, and other legal professionals.
The quarterly publication showcases consumer bankruptcy related material, Supreme Court updates, profiles of NACBA members and programs, previews of NACBA events, as well as, commentary on topics of interest to bankruptcy attorneys.
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Monthly Member Alert
