Bess M. Parrish Creswell
How Judge Creswell rules, drawn from 8 signed orders. Every observation links to the order it came from.
About Judge Creswell
Bess M. Parrish Creswell has served as a United States Bankruptcy Judge for the Middle District of Alabama since April 2018. She became chief judge in October 2020. Before her appointment, she practiced law and clerked for Bankruptcy Judge Ray C. Mullins.
Judge Creswell's practices and standing orders
Rules for cases before Judge Creswell, as published on the court's website (checked October 11, 2026). Judges revise these often, so confirm the current version on the court's site before you file.
Key rules
Contacting chambers
Send settlements and agreed continuances to the designated settlement email by noon on the business day before the hearing, copying opposing counsel and the trustee.
“continuances should be sent no later than 12:00 PM the business day prior to the hearing”
Filing
Submit proposed orders in CM/ECF, and upload an order following a hearing within 14 days.
“the order should be uploaded within 14”
Filing
For Chapter 13 confirmation hearings, make filings by 5:00 p.m. on the fourth full business day before the hearing.
“shall be made no later than 5:00”
Motions
File an affidavit as a separate attachment to a motion to extend or impose the automatic stay.
“All motions to extend or impose the automatic stay should have an affidavit filed as a separate”
Motions
For a motion for relief from stay, attach an affidavit and Fact Summary Sheet as separate docket attachments.
“Movant should attach an Affidavit and”
Standing orders for every case in this court
Orders the court applies to all of its cases, whichever judge has them, as published on the court's website (checked October 11, 2026).
- Amended Administrative Order 2026-03 Regarding the Filing of Deficiency Claims ↗
- Administrative Order 2024-03 on Motions to Transfer Venue ↗
- General Order 2021-02: Procedures for Highly Sensitive Documents ↗
- E-Orders Guidelines and Procedures ↗
- Procedure for Attorneys Filing Redactions ↗
- Amended Order Governing Procedures in Cases Under Chapter 13 ↗
How Judge Creswell decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
A Chapter 13 debtor bears the burden of showing good faith in both the petition and the proposed plan.
“Debtor must show that ‘the plan has been proposed in good faith’ and that ‘filing the petition was in good faith.’”
In In re Shelly H. Moseley, Creswell denied a creditor’s Rule 2004 examination request because it would have circumvented discovery rules in pending state-court litigation.
“the Rule 2004 Request is not a proper use of Rule 2004 discovery; instead, it represents an effort to circumvent the discovery rules of the State Court Litigation.”
A debtor seeking damages for a stay violation should document quantifiable losses; inconvenience and unsupported assertions of lost work or emotional distress do not establish additional actual damages.
“Actual damages must be proven with evidence, and courts have declined to award damages where the debtor fails to identify out of pocket costs the debtor was forced to incur by virtue of the stay violation.”
In Beckon, Creswell allowed a Chapter 7 debtor without mortgage or rent payments to claim the full housing and utilities standard because she paid electricity and water bills; the means test therefore raised no presumption of abuse.
“Debtor is therefore entitled to claim the full $2,197.00 notwithstanding that she has no mortgage or rent obligation.”
Cautions
Equitable concerns do not permit departure from a specific eligibility rule in the Bankruptcy Code.
“The Court cannot ‘contravene specific statutory provisions,’ and must balance the equities in cases ‘within the confines of the Bankruptcy Code.’”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“ORDERED that Creditor’s objection to confirmation is SUSTAINED. Accordingly, confirmation of Debtor’s plan is denied, and his case is DISMISSED.”
“Creditor’s Motion to Dismiss (Doc. 33) is GRANTED, and Debtor’s Chapter 13 case is DISMISSED pursuant to § 109(g)(2).”
“TitleMax’s objection to confirmation (Doc. 20) of Debtor’s case is sustained”
“the motion (Doc. 21) confirming that the stay is not in place is granted”
“ORDERED that the Rule 2004 Request is DENIED.”
“ORDERED that Debtor’s Motion for Discharge is GRANTED.”
“Defendants’ Motion for Summary Judgment is GRANTED and Plaintiff’s Complaint is DISMISSED with prejudice.”
“The Court concludes that Plaintiff offered sufficient evidence to prove a willful violation of the automatic stay under § 362(a), and that the acts of Defendant support an award of actual damages in the amount of $1,875.00.”
“Thus, the Court finds that punitive damages are not warranted in this case.”
“ORDERED that the Motion is DENIED.”
Caseload & timing
From public federal docket records for this judge.
The nine terminated sampled matters lasted 372 to 785 days, with a median of 504 days. Three pending matters are included; one was added after the court listed a later opinion in that case.
Draft for Judge Creswell with the record in hand
Ezel grounds your drafting and research in this profile: what has persuaded Judge Creswell, and what has not, cited to the signed orders.
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