Rachel Ralston Mancl

How Judge Mancl rules, drawn from 7 signed orders. Every observation links to the order it came from.

Court
U.S. Bankruptcy Court for the Eastern District of Tennessee
Position
Bankruptcy judge
Appointed by
U.S. Court of Appeals for the Sixth Circuit
Commissioned
April 11, 2022
Education
University of Tennessee, J.D.; University of Tennessee, M.B.A.
Signed orders read
7

About Judge Mancl

Rachel Ralston Mancl serves as the primary bankruptcy judge for the Greeneville Division of the Eastern District of Tennessee. Before joining the court, she practiced at Hunter, Smith & Davis and clerked for Bankruptcy Judge Marcia Phillips Parsons. She earned law and business degrees from the University of Tennessee.

Judge Mancl's practices and standing orders

Rules for cases before Judge Mancl, 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

Filing

The Northeastern Division guideline cautions that Bankruptcy Noticing Center service cannot satisfy certified mail service for an FDIC-insured depository institution.

“Service by the BNC will never meet the requirement of Fed. R. Bankr. P. 7004(h) (that the FDIC-insured depository institution creditor be served by certified mail).”

Conferences

Judge Mancl conducts hearings in person unless she specifically permits participation by telephone.

“All hearings will be conducted in person unless permission to participate by telephone is specifically given by Judge Mancl.”

Conferences

For a nonevidentiary administrative or contested hearing, attorneys must contact chambers at least 24 hours ahead to request telephone participation, except in emergencies.

“Attorneys who desire to appear and participate telephonically in a non-evidentiary hearing on an administrative or a contested matter must contact chambers for permission to do so at least 24 hours prior to the hearing except in the case of an emergency.”

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 Mancl decides

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

What persuades

The court credits a qualified appraisal's methodology while independently adjusting for material defects and market stigma the appraisal did not fully account for.

“The court assigned significant weight to Mr. Briggs’ appraisal because of his background, his familiarity with the East Tennessee real estate market, and the methodology used to appraise the home.”

Procedural preferences

Failure to comply with Rule 3002.1's notice requirements can support an order preventing undisclosed postpetition charges from becoming a foreclosure default.

“Because the claim holder failed to comply with Rule 3002.1, the court will prohibit the claim holder and its successors, transferees, and other assigns from ever using the nonpayment of any of those fees, expenses, or charges as a basis for declaring a default to foreclose on the debtor’s residence.”

A factual dispute over collateral value and secured status is not resolved against a plausibly pleaded preference claim on a motion to dismiss.

“The Credit Union’s argument to that effect now does not negate that the debtor’s factual allegations under § 547(b)(5) were sufficiently pled.”

Cautions

A clear scheduling order remains controlling unless the court changes it; assuming that an unrelated deadline extension moved trial did not establish excusable neglect.

“Plaintiff’s decision to ignore the trial date in the scheduling order had consequences.”

A knowing breach of contract alone does not satisfy the stringent willful-and-malicious-injury exception to discharge.

“If it were, every knowing breach of contract would be nondischargeable, and that is not the standard for a ‘willful and malicious injury’ under § 523(a)(6).”

Signed rulings

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

In re Peggy C. Manis
2:21-bk-51306-RRM · 2026-03-24
Motion to preclude postpetition fees (Peggy C. Manis) Granted

“Accordingly, the court has determined it is appropriate to grant such relief to the debtor that will prevent the claim holder and its successors, transferees, and other assigns from ever using any postpetition fees, expenses, and charges incurred during this bankruptcy as a basis for declaring a default under the terms of the Reverse Mortgage.”

In re Nicholas Vaughn Morris
2:25-bk-50475-RRM · 2026-02-17
Motion to avoid judicial lien (Nicholas Vaughn Morris) Granted in part

“An order was entered ‘avoiding the judicial lien in part and fixing the amount of the judicial lien at $7,938.50.’”

Morris v. Knoxville TVA Employees Credit Union (In re Morris)
2:25-bk-50475-RRM; 2:25-ap-05010-RRM · 2025-11-14
Motions to dismiss (Knoxville TVA Employees Credit Union) Denied

“On the filing of this memorandum opinion, an order will be entered denying the Credit Union’s motion to dismiss.”

Kruglyak v. Baer (In re Baer)
2:24-bk-50085-RRM; 2:24-ap-05012-RRM · 2025-06-05
Motion for reconsideration (Vladimir R. Kruglyak) Denied

“In conjunction with the filing of this memorandum opinion, an order will be entered denying plaintiff’s motion in its entirety”

Request to revoke discharge (Vladimir R. Kruglyak) Denied

“Thus, plaintiff’s renewed attempt for revocation of the defendant’s discharge will be denied.”

Motion to convert to chapter 13 (Vladimir R. Kruglyak) Denied

“Thus, plaintiff’s renewed attempt at conversion will be denied.”

Kruglyak v. Baer (In re Baer)
2:24-bk-50085-RRM; 2:24-ap-05012-RRM · 2025-03-12
Motion in limine (Vladimir R. Kruglyak) Denied

“In accordance with the memorandum opinion filed herewith, plaintiff’s motion in limine and motion for summary judgment are denied.”

Summary judgment (Vladimir R. Kruglyak) Denied
Scism v. Wise (In re Wise)
2:19-bk-51715-RRM; 2:22-ap-05005-RRM · 2023-09-29
Claim to except debt from discharge (Dallas and Jessica Scism) Denied

“denying that plaintiffs’ claim is excepted from discharge under either 11 U.S.C. § 523(a)(2)(A) or (6)”

Motion for damages for discharge injunction violation (Richard and Pamela Wise) Denied

“Plaintiffs’ actions in connection with the state court action and this adversary proceeding were in no way improper. Debtors’ motion will be denied.”

In re Honey Do Franchising Group, Inc.
2:24-bk-50596-RRM · 2026-04-17

The court directed the debtor to accept or reject required changes within fourteen days; the plan-confirmation objections and lease-assumption motion remained contingent on that later election.

Caseload & timing

From public federal docket records for this judge.

Five post-appointment matters were terminated and supplied no text-grounded contested disposition. The inherited Manis case remained pending in the search metadata and supplied one contested timeline.

Draft for Judge Mancl with the record in hand

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

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