Elizabeth D. Katz

How Judge Katz rules, drawn from 19 signed orders. Every observation links to the order it came from.

Court
U.S. Bankruptcy Court for the District of Massachusetts
Position
Bankruptcy judge
Commissioned
March 13, 2017
Signed orders read
19

About Judge Katz

Elizabeth D. Katz has served as a United States Bankruptcy Judge for the District of Massachusetts since March 2017 and is the court’s chief judge. Her chambers are based in Springfield, Massachusetts.

Judge Katz's practices and standing orders

The court's website lists no individual practices or standing orders of Judge Katz's own (checked October 10, 2026), so the court's local rules and general orders are the place to look (court page ↗).

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 10, 2026).

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

How Judge Katz decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

A proposed Chapter 13 cure through loan modification is not categorically barred, but an objecting party can still raise case-specific feasibility and good-faith evidence.

“the Court is not persuaded that a Chapter 13 plan cannot be confirmed over a creditor's objection solely on the grounds that a loan modification cannot constitute ‘cure’ under § 1322(b)(5).”

Massachusetts homestead protection can extend to a qualifying principal residence that is also used for business activity.

“the Homestead Exemption is intended to apply to residential properties that may also be used for business purposes or in connection with commercial activities so long as the other conditions of the Homestead Statute are satisfied.”

Documents executed as parts of one integrated loan transaction may be read together to resolve ambiguity in a single instrument.

“any potential ambiguity must be resolved by reference to the loan documents as a whole.”

Accessible home equity may defeat an undue-hardship showing when liquidation can satisfy student loans without preventing a minimal standard of living.

“the existence of equity that could be liquidated to satisfy the debts negates any claim that payment of the loans imposes an undue hardship.”

In a nondischargeability dispute, she read the statutory requirement that restitution be payable to a governmental unit separately from any public benefit of the payment.

“the Court must separately find that a debt is both ‘payable to’ and ‘for the benefit of’ a governmental unit.”

Procedural preferences

In Kalesnik v. HSBC Bank USA, she held that the Chapter 13 debtor lacked standing to exercise trustee avoidance powers outside § 522(h), and dismissed the first count.

“For that reason, this Court adopts the majority view and holds that Chapter 13 debtors do not have standing to exercise a trustee’s avoidance powers outside the narrow confines of § 522(h).”

Cautions

A sanctions request must comply with the separate-motion and safe-harbor requirements rather than ask the court to bypass them sua sponte.

“Having failed to comply, the Defendants seek an end run around these procedural requirements by inviting the Court to exercise its sua sponte powers under Rule 9011(c)(1)(B), an invitation which this Court declines.”

She denied approval of a disclosure statement where the proposed plan depended on selling disputed property before determining whether it belonged to the bankruptcy estate.

“the sale may not be authorized under § 363(f)(4) absent such a resolution.”

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

Andrade v. Essenfeld (In re Andrade)
· 2017-07-12

The court dismissed the debtor’s co-ownership sale claim on its own initiative because the authority belonged to the trustee.

In re Unacha; In re Flynn; In re Benoit
18-40036; 18-41098; 18-41136 · 2019-04-23
Objection to chapter 13 plan confirmation (The Bank of New York Mellon) Granted in part

“each of the Objections to the Debtors' Plans will be overruled in part and sustained in part”

Objection to chapter 13 plan confirmation (Federal National Mortgage Association) Granted in part
Objection to chapter 13 plan confirmation (U.S. Bank National Association) Granted in part
Fortin v. Federal National Mortgage Association and Nationstar Mortgage, LLC (In re Fortin)
· 2019-03-05
Motion for partial judgment on the pleadings (Federal National Mortgage Association and Nationstar Mortgage, LLC) Granted

“Accordingly, the Defendants' request for judgment as to Count II will be granted.”

In re Sjogren
· 2017-07-12
Objection to chapter 13 plan confirmation (Chapter 13 trustee) Granted

“the Court will SUSTAIN the Trustee’s objection”

In re Shove
· 2018-05-29
Motion to avoid judicial lien (Richard M. Shove and Kathleen E. Shove) Granted

“the Court will GRANT the Debtors' Motion.”

White v. Gaffney (In re Lloyd)
· 2019-06-28

After its own show-cause order, the court dismissed seven claims for lack of jurisdiction over claims that arose after the bankruptcy petition.

D'Alessio v. CIT Bank, N.A. (In re D'Alessio)
· 2018-06-11
Objection to chapter 13 plan confirmation (CIT Bank, N.A.) Granted

“the Plan Objection will be sustained”

Motion for relief from stay (CIT Bank, N.A.) Granted

“the Motion for Relief from Stay will be granted”

Summary judgment (CIT Bank, N.A.) Granted

“the Summary Judgment Motion will be granted”

Schatz v. U.S. Department of Education, Access Group, Inc., and Massachusetts Educational Financing Authority (In re Schatz)
· 2018-05-02

After trial, judgment entered for the defendants on the debtor’s student-loan discharge complaint.

Goldsmith v. Macri Associates, Inc. (In re E & G Waterworks, LLC)
· 2017-07-27
Motion to compel arbitration (Macri Associates, Inc.) Denied

“The Arbitration Motion will therefore be denied as to Count I.”

Kalesnik v. HSBC Bank USA, National Association and Ocwen Loan Servicing, LLC (In re Kalesnik)
15-30597; 16-3027 · 2017-07-11
Motions to dismiss (HSBC Bank USA, National Association and Ocwen Loan Servicing, LLC) Granted in part

“For all the foregoing reasons, the Court will GRANT IN PART and DENY IN PART the Defendants’ Motion to Dismiss.”

In re Worcester Country Club Acres, LLC
23-40446-EDK · 2023-11-07
Motion to approve disclosure statement (debtor) Denied

“the Debtor’s Motion to Approve the Disclosure Statement for the Plan will be DENIED.”

In re Blumsack
21-40248-EDK · 2023-01-17
Motion to dismiss case (United States trustee) Granted

“confirmation of the Debtor’s Chapter 13 plan must be denied, and the Debtor’s case must be dismissed.”

Objection to chapter 13 plan confirmation (United States trustee) Granted

Draft for Judge Katz with the record in hand

Ezel grounds your drafting and research in this profile: what has persuaded Judge Katz, and what has not, cited to the signed orders.

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