Lisa M Brantley, 667 B.R. 139

Lisa M. Brantley filed a voluntary Chapter 7 bankruptcy petition on August 12, 2023, with assistance from counsel.
Bankruptcy rules required her to file a Financial Management Course Certificate within 60 days after the first meeting of creditors to be eligible for discharge.
Brantley did not file the required certificate by the November 13, 2023 deadline, nor while the case remained open.
The court closed Brantley’s bankruptcy case without a discharge on November 29, 2023, and proper notice of the closure was sent to her and her attorney.
On February 27, 2025—over a year after closure—Brantley moved to reopen the case to file the certificate and seek a discharge, without providing any excuse for the delay.
The court considered whether to grant the motion under § 350(b) and relevant bankruptcy rules, which require "cause" to reopen a case for this purpose.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the case should be reopened to allow late filing of the Financial Management Course Certificate	Brantley argues for reopening the case so she may file the certificate and obtain discharge	No separate defendant; court applied existing law and precedents; emphasized delay and lack of explanation	Motion denied; no cause shown for reopening or retroactive extension

Rosinski v. Rosinski (In re Rosinski), 759 F.2d 539 (6th Cir. 1985) (decisions to reopen bankruptcy cases are within the discretion of the bankruptcy court)
In re Barrett, 569 B.R. 687 (Bankr. E.D. Mich. 2017) (applies four-factor test for motions to reopen to file certificate)
In re Johnson, 500 B.R. 594 (Bankr. D. Minn. 2013) (delayed motion to reopen for discharge denial)
In re Gray, 661 B.R. 570 (Bankr. E.D. Mich. 2024) (precedent denying reopening after significant delay)
In re Parker, 659 B.R. 872 (Bankr. E.D. Mich. 2024) (same)