Hann v. Educational Credit Management Corp. (In Re Hann), 711 F.3d 235

Hann filed Chapter 13; ECMC filed unsecured proof of claim for $54,756.44.
Hann objected, alleging inadequate documentation and pre-petition repayment; requests disallowance or allowance in line with records.
ECMC did not appear at the objection hearing; Hann provided evidence of repayment and an affidavit.
Bankruptcy court sustained Hann’s objection and issued the Claim Order: ECMC’s claim allowed in $0.00.
The Claim Order lacked explicit factual findings; Hann later asserted ECMC had no remaining debt and reopened proceedings after bankruptcy.
BAP affirmed sanctions against ECMC for continuing collection efforts after the Claim Order; Hann obtained judgment and fees/costs as sanctions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the Claim Order adjudicate repayment of the debt?	Hann shows repayment; order implies debt was satisfied.	Order disallowed the claim; it does not determine repayment.	Yes; the Claim Order, read with record, reflected repayment.
Whether sanctions for discharge-injunction violation were proper?	Sanctions warranted for abuse of bankruptcy process.	Sanctions improper if based on unclear order; no clear violation.	Sanctions affirmed on abuse-of-process grounds.
What standard governs interpreting an ambiguous disallowance order?	Record can show intent; ambiguity resolved by reviewing proceedings.	Ambiguity complicates enforcement; need clear language.	Court may infer intent from record; not required to vacate order.

Hoult v. Hoult, 157 F.3d 29 (1st Cir. 1998) (central issue determination in prior trial relied on pivotal questions)
Negrón-Almeda v. Santiago, 528 F.3d 15 (1st Cir. 2008) (courts may discern intention from the record when orders are imprecise)
Sharfarz v. Goguen (In re Goguen), 691 F.3d 62 (1st Cir. 2012) (de novo review of bankruptcy decision on questions of law and fact)