The Fourth Circuit recently issued a published opinion in Dale v. Peoples Bank Corp. addressing a question that arises whenever creditors pursue bank accounts to satisfy a judgment: can a bank be sued for conversion when it turns over funds pursuant to state judgment-enforcement procedures? The court’s answer was a clear no.
In JSmith v. Clancy & Theys, Judge Joseph Callaway addressed a familiar temptation in bankruptcy litigation: trying to convert an ordinary contract dispute into a turnover action under 11 U.S.C. § 542. The court allowed most of the debtor’s claims to proceed—but drew a clear line around turnover.
In Israel v. Zachary, the North Carolina Court of Appeals affirmed that a landlord who interferes with a tenant’s efforts to retrieve property after eviction can be liable for conversionand unjust enrichment, though the court vacated the damages award for lack of sufficient valuation evidence.
In Tederick v. LoanCare, LLC, the Fourth Circuit vacated a summary judgment ruling that had dismissed a consumer class action against mortgage servicer LoanCare under the West Virginia Consumer Credit and Protection Act (WVCCPA). The appellate court held that the statute imposes strict liability, meaning that a borrower does not need to prove the servicer intended to violate the law.
Available at: https://libertystreeteconomics.newyorkfed.org/2026/03/sports-betting-is-everywhere-especially-on-credit-reports/
Summary (Liberty Street Economics + NY Fed Staff Report)
The Federal Reserve’s analysis confirms what many consumer bankruptcy attorneys have been seeing anecdotally: legalized sports betting is not just entertainment—it is increasingly showing up as measurable financial distress.
In Terrance v. Coastal Federal Credit Union, the U.S. District Court for the Eastern District of North Carolina affirmed a bankruptcy court decision imposing $5,000 in sanctions for a willful violation of the automatic stay, while rejecting several broader arguments raised by the pro se debtors on appeal.
The decision provides a useful reminder of two points frequently litigated in stay-violation cases:
