## Facts

- Janis Rogers, an unmarried wage earner employed by General Motors in Flint, Michigan, filed a Chapter 13 petition on June 16, 1986.
- She proposed a Chapter 13 plan requiring payments of $225 per week for four years (total $46,800).
- The plan proposed that she retain a red 1984 Corvette and pay the full secured debt on it ($17,158.97) over the plan term.
- Rogers also owned a second vehicle and proposed to surrender it, keeping only one car.
- Unsecured creditors objected to confirmation, arguing that retaining and fully paying for the Corvette showed she was not committing all disposable income and was acting in bad faith.
- An unsecured creditor also objected that the plan exceeded three years without “cause” as required by 11 U.S.C. § 1322(c) (as then in force).
- The court took into account local conditions, finding that in Flint, Michigan, possession of one vehicle was practically necessary.

## Issues

1. Whether a Chapter 13 plan satisfies disposable-income and good-faith requirements when the debtor retains and pays a secured claim on a relatively expensive vehicle while making substantial plan payments.
2. Whether “cause” existed under 11 U.S.C. § 1322(c) to permit a Chapter 13 plan term longer than three years (four years here).

## Decision

- The court overruled the unsecured creditors’ objections and allowed confirmation of the plan.
- The court held that retaining one vehicle for transportation in the debtor’s locality was not, by itself, inconsistent with committing disposable income or with good faith.
- The court found sufficient “cause” under § 1322(c) to extend the plan term beyond three years to four years.
- The plan was permitted to proceed with retention of the Corvette and payment of the full secured debt while the debtor made the proposed weekly payments.

## Legal Principles

- A Chapter 13 debtor may retain a reasonably necessary automobile, even if relatively high-value, if the plan otherwise reflects commitment of disposable income and good faith.
- Good faith and disposable-income analysis may consider practical necessities and local conditions, including whether reliable transportation is needed for employment and daily life.
- Under former 11 U.S.C. § 1322(c), a plan term exceeding three years may be approved “for cause,” including when a longer term supports feasibility and permits repayment of secured obligations while improving treatment of unsecured creditors.

## Conclusion

The bankruptcy court confirmed a four-year Chapter 13 plan, concluding that keeping a single vehicle for necessary transportation did not alone show lack of disposable-income commitment or bad faith, and that the debtor’s repayment structure provided “cause” to extend the plan beyond three years under § 1322(c).


In re Rogers, 65 B.R. 1018 (Bankr. E.D. Mich. 1986)