Brian S. Kruse

How Judge Kruse rules, drawn from 20 signed orders. Every observation links to the order it came from.

Court
U.S. Bankruptcy Court for the District of Nebraska
Position
bankruptcy
Commissioned
2020-03-17
Education
University of Nebraska College of Law, 2000
Signed orders read
20

How Judge Kruse decides

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

What persuades

A confirmed Chapter 11 plan replaces pre-confirmation loan rights, so enforcement must rest on a valid post-confirmation default.

“The confirmed plan modified the debtor’s obligation to the bank, including the ‘terms of repayment’.”

Procedural preferences

When a complaint groups multiple debtors together, knowledge and intent must be pleaded separately for each debtor.

“Dischargeability is determined debtor by debtor.”

Cautions

Counsel seeking payment protection should accurately disclose fee timing and source; post-petition payments may be subject to disgorgement.

“James Bachman must disgorge the $7,500 cash-retainer payment, the $7,500 from check 5226, and the $15,500 the debtor paid post-petition, for a total of $30,500 to Lauren Goodman, Chapter 7 trustee.”

Signed rulings

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

In re Zuhlke
24-40267 · 2026-08-18
Trustee motion to authorize llc dissolution (Chapter 7 trustee) Granted

“The Chapter 7 trustee is authorized, acting as the sole member of the LLCs, to dissolve Joysprings Properties LLC and Diamond Z Farms LLC, and to sell their assets under Nebraska law as part of the winding up.”

Trustee motion for turnover of vehicles (Chapter 7 trustee) Granted

“Alden and Lisa Zuhlke, Christian Zuhlke, Joysprings Properties, LLC, and Diamond Z Farms LLC are ordered to turn all vehicles over to the trustee.”

Trustee request to sell estate vehicles (Chapter 7 trustee) Moot / procedural

“The trustee may seek to sell them but must file a new motion under 11 U.S.C. § 363.”

In re Nebraska Peace of Mind Behavioral Health, LLC
26-40156 · 2026-08-17

The court identified confirmation defects and permitted a timely modification rather than entering a final confirmation ruling.

Dottore v. Wagner (In re Wagner)
26-08006 · 2026-08-10
Motion to dismiss nondischargeability complaint (Andrew R. Wagner and Maddison A. Wagner) Granted

“The debtors’ motion to dismiss is granted with leave to amend.”

D'Saachs v. Sell (In re Sell)
25-08010 · 2026-07-07
Motion to amend findings and conclusions (Christina D'Saachs) Denied

“The plaintiff’s motion is denied to the extent it seeks to reverse any findings of fact or conclusions of law.”

NebraskaLand Bank v. Spencer (In re Spencer)
25-04006 · 2026-06-11
Nondischargeability claim section 523 a 2 b (NebraskaLand Bank) Granted in part

“$191,000 of the debt owed by the debtor and defendant Cleo G. Spencer to the plaintiff NebraskaLand Bank is excepted from discharge under 11 U.S.C. § 523(a)(2)(B).”

D'Saachs v. Sell (In re Sell)
25-08010 · 2026-06-02
Objection to discharge section 727 (Christina D'Saachs) Denied

“The objection to discharge is denied for the reasons stated on the record after the hearing.”

Nondischargeability claim section 523 a 2 a (Christina D'Saachs) Granted in part

“The objection to dischargeability is granted in part. Of the total debt owed by the defendant, $9,629 is excepted from discharge.”

In re Watson
25-80538 · 2026-04-08
Motion to reopen bankruptcy case (Michael Watson) Granted

“The motion to reopen is granted.”

Motion for relief from stay for state court proceedings (David Hospodka) Granted in part

“To the extent necessary, relief from stay is granted for the foregoing, with waiver of the stay under Fed. R. Bankr. P. 4001(a)(4).”

In re Berkshire
25-80366 · 2026-03-31
Trustee motion for sanctions (Chapter 7 trustee) Granted in part

“The trustee is awarded $1,170.47 charged by the security company, $128 charged by the garage door company, and attorney’s fees of $22,764.50.”

D'Saachs v. Sell (In re Sell)
25-08010 · 2026-03-17
Summary judgment (Jayme Davis Sell and Andra Lynne Sell) Denied

“For the above reasons, the defendants’ motion for summary judgment is denied.”

In re Berkshire
25-80366 · 2026-03-12
Trustee motion to sell real estate (Chapter 7 trustee) Granted

“The trustee’s motion to sell (Doc. #438) is approved.”

Trustee motion to surcharge collateral (Chapter 7 trustee) Granted in part

“The trustee’s motion to surcharge (Doc. #489) is approved in part.”

In re Thompson
25-41293 · 2026-03-10
Motion for turnover of garnished wages (Benjamin and Brittany Thompson) Denied

“IT IS THEREFORE ORDERED, the debtors’ motion is denied.”

Motion to release garnishment (Benjamin and Brittany Thompson) Denied
Motion for automatic stay sanctions (Benjamin and Brittany Thompson) Denied
In re EAD Constructors, Inc.
25-81134 · 2026-03-05
Motion for relief from stay to arbitrate (Corbion) Granted

“Corbion’s motion for relief from the automatic stay (Doc. #61) is granted.”

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