Erneicia Brown, 634 B.R. 748

Debtor filed a Chapter 7 petition on May 28, 2019; §341 first meeting was set for July 3, 2019.
Rule 1007(b)(7) required the Debtor to file the Official Form 423 (Financial Management Course Certificate) within 60 days after the §341 date (deadline Sept. 3, 2019).
Debtor did not file the certificate or move to extend the deadline; the case was closed without a discharge on Sept. 27–29, 2019, with mailed/e‑filed notices to Debtor and counsel.
Debtor completed the debtor‑education course on Nov. 15, 2021 and filed a motion to reopen on Dec. 26, 2021 (≈15 months after closure) to file the certificate and obtain a discharge.
The court applied a four‑factor test (reasonable explanation, timeliness, counsel fault, creditor prejudice) and denied the motion to reopen and any retroactive extension of time.

Issue	Debtor's Argument	Opposing Argument	Held
Whether Debtor showed “cause” to reopen the closed case under 11 U.S.C. §350(b)	Debtor completed the course and seeks to reopen to file the certificate and obtain a discharge	Long, unexplained 15‑month delay after notice; Debtor and counsel received notices; no excuse shown; reopening is discretionary	Denied — no cause shown; all four factors weigh against reopening
Whether the court should grant a retroactive extension to file Official Form 423 under Rules 9006(b)(3) /1007(c)	Requests retroactive enlargement so discharge can be entered	Extensions require cause and notice; Debtor failed to show cause or timely action	Denied — no retroactive extension granted
Whether creditors would be prejudiced by reopening	Debtor: reopening would not prejudice parties	Court: long delay undermines statutory purpose and is unfair to creditors	Court finds prejudice factor weighs against reopening

Rosinski v. Rosinski, 759 F.2d 539 (6th Cir. 1985) (reopening decisions committed to bankruptcy court's discretion)
In re Barrett, 569 B.R. 687 (Bankr. E.D. Mich. 2017) (applied four‑factor test and denied motion to reopen to file financial management certificate)
In re Rivera, 628 B.R. 309 (Bankr. E.D. Mich. 2021) (denied reopening where delay was lengthy and factors weighed against relief)