1st Circuit

Marrama v. Citizens Bank of Massachussetts, et al. (10/31/05 - No. 04-9009)

Section 706(a) does not confer an "absolute" right to convert to Chapter 13. Where debtor acknowledged concealing transactions intended to protect his assets from creditors, the court may deny such conversion.

7th Circuit

Thomas v. Money Mart Financial Servs., Inc. (11/04/05 - No. 05-1176)

Bankruptcy Court's order finding that defendant did not violate automatic stay by presenting plaintiff's checks for payment postpetition is affirmed where plaintiff had not received a discharge when defendant presented the checks.

Hallmark v. Athens/Alpha Gas Corp. (11/04/05 - No. 05-6020)

Order denying plaintiffs' claim for administrative expenses reversed where there existed a post-petition transaction by plaintiffs that provided a tangible benefit to the Estate.