Mathieu Reginald Reyna, 657 B.R. 845

Prior to the bankruptcy, Erik Randesi (individually and on behalf of Premiere Renovations, LLC and A Affordable Driving School, Inc.) filed three lawsuits in Virginia Beach Circuit Court against debtor Mathieu Reginald Reyna, concerning business disputes and alleged personal wrongs.
The three lawsuits consisted of claims for business torts (breach of fiduciary duty, conversion, computer fraud, etc.) and a separate defamation suit; Reyna was co-owner/co-manager of both companies with Randesi.
Temporary injunctions were granted in state court, removing Reyna’s management roles and restricting his access to company assets; dissolution and winding up proceedings for Premiere were also initiated.
Reyna filed for Chapter 7 bankruptcy, which triggered the automatic stay and paused all state court litigation against him.
Movants (Randesi and entities) filed a motion for relief from stay to pursue their state law claims in state court; both Reyna and the Chapter 7 Trustee opposed, citing judicial economy and estate protection.
The Bankruptcy Court considered the parties’ stipulations, evidence, and arguments before deciding whether to lift the stay under the Robbins factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether bankruptcy court should lift stay to allow state litigation to proceed (Robbins factors)	Robbins factors favor lifting stay; all claims are state law, judicial economy best served in state court, bankruptcy court can protect estate	Litigation involves bankruptcy issues; estate at risk in state court; judicial economy better in bankruptcy court	Stay lifted; state court to adjudicate all claims, estate protected by trustee’s intervention
Jurisdiction over defamation claim in bankruptcy court	Bankruptcy court cannot hear state defamation claim; it’s a personal injury tort	No specific argument; main opposition to proceeding in state court	Court lacks jurisdiction; defamation claim must proceed in state court
Risk to bankruptcy estate if litigation is in state court	State court can address claims without jeopardizing estate; creditors will return to bankruptcy court for enforcement/discharge determination	Trustee not a party in state court; risk to estate's main asset (Premiere interest)	Trustee must intervene in state proceedings; protections ordered for the estate
Whether all litigation should proceed together for judicial economy	Claims are factually intertwined, best for one forum	Duplicative litigation risks; bankruptcy court should handle discharge and merits	State court better positioned; all facts and claims sufficiently related for single adjudication

Robbins v. Robbins (In re Robbins), 964 F.2d 342 (4th Cir. 1992) (establishes the three-factor test for lifting the automatic stay)
Butner v. United States, 440 U.S. 48 (1979) (property rights in bankruptcy determined by state law)