Bess M. Parrish Creswell

How Judge Creswell rules, drawn from 8 signed orders. Every observation links to the order it came from.

Court
U.S. Bankruptcy Court for the Middle District of Alabama
Position
Bankruptcy judge
Appointed by
U.S. Court of Appeals for the Eleventh Circuit
Commissioned
April 16, 2018
Education
Campbell University, B.B.A., 2001; Campbell University, M.B.A., 2001; Wake Forest University School of Law, J.D., 2004
Signed orders read
8

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).

Key rules from these orders · The court's local rules ↗

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.

In re Richard Devaughan
1:23-bk-10150 · 2023-07-05
Objection to plan confirmation (creditor Bonita Dennard) Granted

“ORDERED that Creditor’s objection to confirmation is SUSTAINED. Accordingly, confirmation of Debtor’s plan is denied, and his case is DISMISSED.”

In re Levarus Vashaun Holmes
2:23-bk-30551 · 2023-09-11
Motion to dismiss bankruptcy case (U.S. Bank National Association) Granted

“Creditor’s Motion to Dismiss (Doc. 33) is GRANTED, and Debtor’s Chapter 13 case is DISMISSED pursuant to § 109(g)(2).”

In re Gregory Mayo
1:21-bk-10156 · 2021-09-30
Objection to plan confirmation (TitleMax of Alabama, Inc.) Granted

“TitleMax’s objection to confirmation (Doc. 20) of Debtor’s case is sustained”

Motion to confirm automatic stay not in place (TitleMax of Alabama, Inc.) Granted

“the motion (Doc. 21) confirming that the stay is not in place is granted”

In re Shelly H. Moseley
3:24-bk-81498 · 2025-07-22
Rule 2004 examination request (creditor Johnny Ray Jenkins) Denied

“ORDERED that the Rule 2004 Request is DENIED.”

In re Jon Raiford
3:20-bk-80560 · 2024-12-05
Motion for chapter 13 discharge (debtor Jon Raiford) Granted

“ORDERED that Debtor’s Motion for Discharge is GRANTED.”

Semantha Santangelo v. Richard Clarvit and Lilas Ayundeh
3:22-ap-08002 · 2022-08-04
Summary judgment (defendants Richard Clarvit and Lilas Ayundeh) Granted

“Defendants’ Motion for Summary Judgment is GRANTED and Plaintiff’s Complaint is DISMISSED with prejudice.”

Wilma Yvon Wingfield v. Block, Inc.
1:25-ap-01019-BPC · 2026-02-26
Request for actual damages for automatic stay violation (debtor) Granted in part

“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.”

Request for punitive damages for automatic stay violation (debtor) Denied

“Thus, the Court finds that punitive damages are not warranted in this case.”

In re Paula Denise Beckon
25-81296-BPC · 2026-09-18
Motion to dismiss bankruptcy case (Bankruptcy Administrator) Denied

“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

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