As reported by Robin Miller of CBAR:
Agreeing with the one other Court of Appeals decision on the issue, In re Davis, 716 F.3d 331 (4th Cir. 2013), and with what it called the majority view on the issue, the Eleventh Circuit Court of Appeals today held that a Chapter 13 debtor may strip a wholly-unsecured lien from the debtor’s principal residence (or other collateral) even when the debtor is ineligible for a discharge.
Declaring that “BAPCPA did not amend 506 or 1322(b), so the analysis permitting strip offs in Chapter 20 cases is no different than that in any other Chapter 13 case,” the court concluded that “the debtor’s ineligibility for a discharge is irrelevant to a strip off in a Chapter 20 case.”
In re Scantling, Case No.13-10558 (11th Cir., June 18, 2014)