Carlota Böhm

How Judge Böhm rules, drawn from 22 signed orders. Every observation links to the order it came from.

Court
U.S. Bankruptcy Court for the Western District of Pennsylvania
Position
bankruptcy
Commissioned
2011-11-28
Signed orders read
22

How Judge Böhm decides

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

What persuades

Relief from a final order under the catchall provision requires circumstances severe enough to create extreme and unexpected hardship.

“Relief in this manner is only appropriate in ‘extraordinary circumstances where, without such relief, an extreme and unexpected hardship would occur.’”

Prompt action after learning of a bankruptcy is important when later seeking retroactive relief from the automatic stay.

“It is extremely significant that Movants were aware of Shoppingtown’s bankruptcy in 2021 but did not take steps to seek relief until 2026.”

Issue preclusion does not establish nondischargeability on summary judgment when the prior court did not actually resolve the required fraudulent intent.

“As clarified at oral argument, fraud was not actually found by the State Court; rather, Mr. Knoll’s position is that the findings of fact taken together support a finding of fraud.”

Procedural preferences

Leaves genuinely disputed facts for a later stage instead of resolving them on a motion to dismiss.

“Resolution of that factual dispute is not appropriate at this stage of the proceedings.”

Treats a plan administrator expressly vested with trustee powers as eligible for the statutory extension applicable to estate claims.

“Based on the foregoing, this Court concludes that the extension provided in §108 applies. This action is timely, and the request to dismiss the Complaint is denied.”

Signed rulings

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

Bernstein v. Meyer, Unkovic & Scott LLP (In re 5171 Campbells Land Co., Inc.)
21-2063-CMB · 2026-08-12
Summary judgment (Meyer, Unkovic & Scott LLP and Robert E. Dauer Jr.) Granted in part

“this Court finds the Motion must be granted in part and denied in part.”

In re Angelica Sue Botti
21-21934-CMB · 2026-07-20
Motion to reopen bankruptcy case (Angelica Sue Botti) Denied

“the Motion to Reopen Case and for Relief from Order Approving Settlement (Doc. 126) and Order Dismissing Case (Doc. 134) Pursuant to 11 U.S.C. § 350(b), Fed.R.Bankr.P. 5010, 9024, and Fed.R.Civ.P. 60(b) (Doc. No. 146) filed by Angelica Sue Botti is DENIED.”

In re Shoppingtown Mall NY LLC
19-23178-CMB · 2026-08-27
Motion to reopen bankruptcy case (Nancy Chappell, Kevin C. Hicks, and Jessica Saum) Denied

“In consideration of all five Roberts factors, the Court finds that the Motion must be denied.”

Thornton-Illar v. Semanderes et al. (In re Odyssey Contracting Corp.)
15-22330-CMB; 23-2003-CMB · 2026-04-20
Motions to dismiss (Nicholas S. Semanderes, Houston Industrial Corporation, Geronimo Painting Co., and Amari Painting and Lining, LLC) Granted in part

“the Motions to Dismiss will be granted in part and denied in part.”

Knoll v. Uku (In re Uku)
21-21712-CMB; 21-2104-CMB · 2024-04-24
Summary judgment (Charles A. Knoll Jr.) Denied

“Mr. Knoll failed to show that the State Court findings and application of collateral estoppel are sufficient to meet his burden to establish non-dischargeability of the debt. Accordingly, the Motion must be denied.”

JTS Capital 3 LLC v. Pittsburgh Development Group, LLC (In re Fontana)
22-22293-CMB; 23-2010-CMB · 2024-02-22
Petition to open or strike confessed judgment (Pittsburgh Development Group, LLC) Granted in part

“PDG’s request to open the confessed judgment is granted to permit an adjudication on the merits. To the extent PDG also sought to strike the judgment, that argument is deemed abandoned, and the request is therefore denied.”

LWBC, LLC v. Rosenberg (In re Rosenberg)
21-20791-CMB; 21-2092-CMB · 2022-08-26
Adversary complaint to deny discharge (LWBC, LLC) Granted

“The request for denial of discharge in the Complaint to Determine Dischargeability of Debts is GRANTED pursuant to 11 U.S.C. §727(a)(4)(A).”

Bernstein v. Meyer, Unkovic & Scott LLP (In re 5171 Campbells Land Co., Inc.)
19-22715-CMB; 21-2063-CMB · 2022-07-25
Motions to dismiss (Meyer, Unkovic & Scott LLP and Robert E. Dauer Jr.) Denied

“Based on the foregoing, Defendants’ Motion to Dismiss is denied.”

In re Salem Consumer Square OH LLC
21-20020-CMB · 2021-07-14
Motion to dismiss or convert chapter 11 case (BELFOR USA Group, Inc.) Denied

“this Court finds that the Motions must be denied based on the record at this time.”

Motion to appoint chapter 11 trustee (BELFOR USA Group, Inc.) Denied

“the appointment of a trustee is denied without prejudice at this time.”

Rubash v. United States Department of Education (In re Rubash)
18-20449-CMB; 18-2028-CMB · 2020-05-19
Summary judgment (United States Department of Education) Granted

“The United States is entitled to judgment as matter of law, and the Motion for Summary Judgment is granted.”

Lepre v. Milton (In re Milton)
16-20747-CMB; 16-2127-CMB · 2019-02-04
Adversary complaint to deny discharge (Gerald S. Lepre Jr.) Denied

“The Court finds no basis to deny Debtor’s discharge or except Mr. Lepre’s debt from discharge.”

Adversary complaint to determine dischargeability (Gerald S. Lepre Jr.) Denied
In re Wagle, LLC
16-21169-CMB · 2017-08-16
Objection to plan confirmation (Lynn Stone McLaughlin) Granted in part

“the Court will sustain the McLaughlin Objection insofar as it contends that the Amended Plan is not fair and equitable because equity is retaining its interests while unsecured claims are not being paid in full”

Caseload & timing

From public federal docket records for this judge.

The duration summary remains limited to the original terminated matter; the pending adversary proceeding was added to recover a motion timeline.

Draft for Judge Böhm with the record in hand

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