In re Williams — 9th Cir. BAP (argued July 16, 2026)
The United States Bankruptcy Appellate Panel of the Ninth Circuit hears argument in In re Williams, an appeal from a bankruptcy adversary proceeding. At the heart of the case is whether a twenty-year delay in pursuing a discharge determination for a fraud judgment can bar the claim under the doctrine of laches—and whether the accrual of more than six hundred thousand dollars in statutory interest on that judgment constitutes the kind of prejudice that makes laches available. The underlying judgment stems from a 2002 fraud finding against the debtor, who later filed for bankruptcy without listing the debt. The creditor, Thaddeus Williams, renewed the judgment periodically under state law but took no enforcement steps for two decades. Williams has since passed away, and his successors in interest now seek to establish that the debt cannot be discharged. The bankruptcy court granted summary judgment to the debtor on laches grounds, finding that the enormous interest burden coupled with the delay was inherently prejudicial. The appellants argue that statutorily mandated interest can never, as a matter of law, constitute prejudice for purposes of an equitable defense like laches.
In re Williams (No. 25-1214) — United States Bankruptcy Appellate Panel of the Ninth Circuit, argued July 16, 2026.
- 0:00Introduction
- 1:43advocate_intro
- 2:43Laches
- 5:58Section 523(a)(3)(B) and Fraud Discharge
- 7:08advocate_intro
- 16:06Section 523(a)(19) and the Need for a Proceeding
- 20:38Submitted for Decision