In reJanssen, 396 B.R. 624 (Bankr. E.D. Pa. 2008) (Frank) (Violation of § 1327(a) can be remedied under § 105(a). Closed case is reopened to permit prosecution of adversary proceeding alleging that mortgage creditor failed to properly apply payments to prepetition arrearage.).

In re Dendy, 396 B.R. 171 (Bankr. D.S.C. 2008) (Waites) (Confirmation of properly noticed plan that treated second mortgage as wholly unsecured and void is binding on creditor that failed to object but lienholder is not obligated to release or cancel mortgage after discharge; in rent and in personam obligations are satisfied and debt is uncollectible but mortgagee did not violate confirmed plan, confirmation order or discharge injunction by failing to take independent steps to release mortgage of record. Confirmation voided mortgage and court can order that recorder reflect mortgage was voided.).

In re Lemma, 394 B.R. 315, 322-24 (Bankr. E.D.N.Y. 2008) (Grossman) (Confirmed plan that cures default and maintains payments trumps relief from codebtor stay under § 1301(c)(2) notwithstanding prepetition judgment of foreclosure and postpetition termination of § 362(a) stay under § 362(c)(3). “The only effect termination of the stay had on this case was to permit the Bank to proceed against Debtors in state court…. [T]here is nothing in the Code to even suggest that once the stay is terminated, Debtors can no longer bind the Bank under a plan which implements the cure and reinstatement provisions provided in the Bankruptcy Code…. The Bank is now barred by res judicata from arguing that Debtors had no right to cure and reinstate the mortgage and note. . . . [E]ven where the stay has been terminated preconfirmation by operation of law under section 362(c)(3) . . . the debtor still retains the right to bind the creditors under a confirmed plan [T]his Court declines to follow [In re Cline, 386 B.R. 344 (Bankr. N.D. Ala. 2008).]”).

See Also Bankruptcy Boston