In re Pajian, 785 F.3d 1161

Debtor Edward Pajian filed Chapter 13 on June 25, 2013; the clerk’s notice set a 90-day proof-of-claim deadline under Fed. R. Bankr. P. 3002(c).
Lisle Savings Bank (creditor) filed a proof of claim on January 21, 2014 — more than three months after the 90-day deadline. The claim included a secured mortgage claim on commercial property and an unsecured deficiency claim from a state foreclosure.
Pajian objected that the late-filed claim was untimely under Rule 3002(c); the Bank argued (1) secured creditors need not file to receive plan distributions, (2) it had filed an informal proof earlier, and (3) Rule 3002(c) does not apply to secured claims.
The bankruptcy court rejected arguments (1) and (2) but accepted (3): it disallowed the unsecured part but allowed the secured portion as timely (filed before plan confirmation).
Pajian took a direct appeal to the Seventh Circuit, which reviewed the legal issue de novo and certified it as one of public importance and conflicting lower-court authority.

Issue	Pajian's Argument	Lisle Savings Bank's Argument	Held
Does Rule 3002(c)’s 90-day filing deadline apply to secured claims?	Rule 3002(c) applies to all claims, so secured claims filed after 90 days are untimely and must be disallowed.	Rule 3002(c) applies only to unsecured creditors; secured creditors may file up until plan confirmation.	Rule 3002(c) applies to all claims, including secured claims; the Bank’s secured claim was untimely and should have been disallowed.

Adams v. Adams, 738 F.3d 861 (7th Cir.) (standard of de novo review for issues of law)
In re Penrod, 50 F.3d 459 (7th Cir.) (secured creditor’s lien survives discharge; failure to file claim does not defeat lien)
Ernst & Young LLP v. Baker O’Neal Holdings, Inc., 304 F.3d 753 (7th Cir.) (post-confirmation offers of proof and limits on unwinding confirmed plans)
Adair v. Sherman, 230 F.3d 890 (7th Cir.) (limitations on disturbing confirmed plans post-confirmation)