6th Circuit Ruskin v. DaimlerChrysler (10/04/05 - No. 03-1087) Where a debtor's actions provide cause for lifting the automatic stay under 11 U.S.C. section 362(d), the debtor generally cannot move to reclassify the deficiency resulting from the sale of the underlying repossessed collateral as an unsecured claim. 7th Circuit Van Diest Supply Co. v. Shelby County (10/03/05 - No. 03-4144) Dismissal of plaintiff's claim for conversion is affirmed where plaintiff did not present evidence sufficient to prove that it had ownership of the property in dispute. 8th Circuit Hollingsworth v. Kaler (10/03/05 - No. 05-6015) Creditor was entitled to distribution from debtor's bankruptcy estate, even though its claims were untimely filed, since the claims were unsecured claims which were entitled to payment after timely filed unsecured claims were paid in full pursuant to 11 U.S.C. section 726(a)(3). Martens v. Countrywide Home Loans (10/03/05 - No. 05-6023) The Bankruptcy Court's grant of relief from an automatic stay is affirmed over plaintiff-debtor's claim that defendant-creditor violated the Fair Debt Collection Practices Act.