Carolyn Dontae Ivery, 667 B.R. 317

Carolyn Dontae Ivery (Debtor) filed a Chapter 13 bankruptcy in January 2020; her plan was confirmed in May 2020 and provided for full payment to her mortgage lender with no payments to unsecured creditors.
The debtor completed all required plan payments by July 19, 2024, and the trustee filed a Notice of Completion.
On August 18, 2024, after plan completion but before discharge, the debtor’s house (the plan’s collateral) was destroyed by fire and she received insurance proceeds.
The trustee objected, arguing the insurance proceeds were non-exempt bankruptcy estate property that should go to creditors.
The debtor moved for entry of discharge, arguing that the plan could not be modified post-completion and that, in any event, the proceeds were exempt under Mississippi law.
The court held a hearing, considered briefs, and limited its holding to whether post-completion modification was permissible—never reaching the exemption issue.

Issue	Ivery's Argument	Trustee's Argument	Held
Can a confirmed Chapter 13 plan be modified after all plan payments are made?	Modification not allowed after payments completed.	Insurance proceeds are non-exempt and should go to creditors; modification still possible.	No modification allowed once plan payments are complete.
Are insurance proceeds post-completion property of estate, subject to distribution?	Insurance proceeds are exempt (if at issue).	Proceeds are non-exempt, estate property.	Exemption issue is moot since proceeds are not reachable.

In re Meza, 467 F.3d 874 (5th Cir. 2006) (Chapter 13 plan cannot be modified under § 1329(a) after debtor completes all plan payments)
In re Coastal Plains, Inc., 179 F.3d 197 (5th Cir. 1999) (Debtor's affirmative duty to disclose all assets in bankruptcy)
In re Flugence, 732 F.3d 126 (5th Cir. 2013) (Debtor cannot keep undisclosed estate assets acquired during bankruptcy)
In re Arnold, 869 F.2d 240 (4th Cir. 1989) (Prevents debtor gamesmanship regarding plan completion and modification)