Wendy Marie Morrison, 10-10365

Debtor Wendy Morrison filed Chapter 7 in 2010; BA sought dismissal for abuse under 707(b)(1)-(3).
Dispute centers on household size for means test; Form B22A shows one-person household but CMI above median for one.
Debtor lived with a boyfriend, sharing expenses; mortgage paid by boyfriend; debtor pays utilities/food for both.
Parties stipulated that the appropriate test is the economic unit, not heads-on-beds or IRS-dependency methods, for this case.
Court finds the Debtor and boyfriend form a single economic unit, yielding a two-person household under the means test.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper meaning of 'household' for means test	BA: two-person household; Debtor: one person	Debtor: one person; wants minimalist interpretation	Economic unit approach controls; household size is two
Admissibility of external definitions (Census/IRS)	Census/IRS definitions support larger households	Definitions misalign with means test purposes	These external definitions are not controlling; economic unit prevails
Application of economic unit factors	Economic unit includes those sharing income/expenses	Debtor may not be part of a larger unit	Court uses case-by-case factors to determine unit; two-person unit here
Impact on Form B22A calculations	Accounting for two-person unit changes deductions	Debtor's liability not affected	Form B22A treatment remains consistent with two-person unit; motions resolved on merits

In re Smith, 396 B.R. 214 (Bankr. W.D. Mich. 2008) (adopts heads-on-beds unless plain meaning dictates otherwise)
In re Ellringer, 370 B.R. 905 (Bankr. D. Minn. 2007) (endorses broader concept of household when appropriate)
In re Jewell, 365 B.R. 796 (Bankr. S.D. Ohio 2007) (rejects strict heads-on-beds; favors economic unit balancing means test goals)
Herbert v. E.g., 405 B.R. 165 (Bankr. W.D.N.C. 2008) (endorses economic unit as correct approach; rejects IRS/dependency approach)