Sawsan Aziz, 622 B.R. 694

Debtor filed a Chapter 7 petition on October 30, 2015; meeting of creditors set for December 9, 2015.
Debtor was required to file Official Form 423 (certificate of completion of a post-petition financial management course) within 60 days after the §341 meeting (deadline Feb. 8, 2016).
Debtor did not file the Certificate by the deadline; the case was closed on Feb. 9, 2016 without a discharge for that reason; the Debtor was mailed notice explaining the deficiency on Feb. 11, 2016.
On Dec. 4, 2020 (about 4 years, 8 months later) the Debtor moved to reopen the case to file the Certificate and obtain a discharge, claiming (without producing the form) that he completed the course on Feb. 4, 2016.
The Court applied a four-factor test (reasonable explanation, timeliness, fault of counsel, creditor prejudice) and found no cause to reopen or to grant a retroactive extension of the filing deadline.
The Court denied the motion to reopen; the Debtor is not barred from filing a new bankruptcy case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is "cause" to reopen the closed Chapter 7 case so Debtor can file Official Form 423 and obtain a discharge	Debtor: completed the course (Feb. 4, 2016) and should be allowed to reopen to file the Certificate and receive a discharge	Court/Opposing view: Debtor offered no valid explanation for failing to file the Certificate or for waiting >4.5 years after notice that case closed without discharge; reopening would prejudice creditors and undermine statutory scheme	Denied — no cause shown to reopen the case
Whether to grant a retroactive enlargement of time to file the Certificate under Rule 1007(c)/9006(b)(3)	Debtor seeks retroactive extension so the late-filed Certificate can support a discharge	Court: extensions require cause and notice; extraordinary delay and lack of explanation weigh against extension; policy goal of immediate post-petition education undermined by long delay	Denied — no retroactive extension granted

Rosinski v. Rosinski (In re Rosinski), 759 F.2d 539 (6th Cir. 1985) (decision to reopen a bankruptcy case is committed to the bankruptcy court's discretion)
In re Barrett, 569 B.R. 687 (Bankr. E.D. Mich. 2017) (denying reopening where debtor delayed many years; applies four-factor cause test)
In re Smith, 620 B.R. 888 (Bankr. E.D. Mich. 2020) (denial of reopening after multi-year delay)
In re Kessler, 588 B.R. 191 (Bankr. E.D. Mich. 2018) (denial where long delay prevented relief)
In re Johnson, 500 B.R. 594 (Bankr. D. Minn. 2013) (denial of reopening after multi-year delay)