Morris v. Quigley, 673 F.3d 269

Debtor Susan Quigley filed a Chapter 13 petition on January 11, 2008.
On Schedule B she listed two ATVs as personal property and on Schedule D listed them as secured collateral; she planned to surrender them.
Schedule B also listed a 2004 Ford truck owned by her ex-boyfriend; the title lists Debtor but the ex-boyfriend paid and was a co-debtor.
On Form B22C she deducted the ATV and truck payments as expenses, despite plan intended surrender and no ongoing payments.
The Trustee objected, arguing the Debtor’s projected disposable income overstated by deducting nonpaid vehicle payments; bankruptcy court split on the ATV issue; district court affirmed; Fourth Circuit reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether projected disposable income may reflect known changes in expenses (ATV payments) not actually paid.	Morris argues the Debtor’s known future expenses should reduce disposable income.	Quigley contends Lanning allows only six-month income data and precludes adjustments for such expenses.	Yes; projected disposable income must account for known changes in expenses.

Hamilton v. Lanning, 130 S. Ct. 2464 (2010) (permits adjustments for known or virtually certain changes in income/expenses in calculating projected disposable income)
Ransom v. FIA Card Servs., N.A., 131 S. Ct. 716 (2011) (addresses car ownership costs under the expenses formula in §1325(b)(3))
In re Darrohn, 615 F.3d 470 (6th Cir. 2010) (rounds that changes in expenses may be considered in projected disposable income)
In re Turner, 574 F.3d 349 (7th Cir. 2009) (pre-Lanning authority aligning with allowing adjustments for known changes)