In re Koshinski — 9th Cir. BAP (Sep 10, 2026)

No. 26-1073 Argued September 10, 2026 Published October 7, 2026

The Ninth Circuit Bankruptcy Appellate Panel hears In re Koshinski, a dispute over whether an old judgment still supports a claim for payment in bankruptcy. A Nevada judgment was entered against Monika Koshinski in 2018. John White, acting as executor of the judgment creditor's estate, sought payment on that judgment in her bankruptcy. The attempt to renew it before the bankruptcy filing was defective, a point the parties no longer dispute. The bankruptcy judge disallowed the claim because the judgment had expired before she filed. White's appeal turns on a Nevada emergency directive issued during the COVID-19 pandemic, which paused certain deadlines for starting legal actions. His lawyer will argue that renewing a judgment continues a pending legal action and falls within that pause. Koshinski's lawyer will contend that the directive covers starting a lawsuit, not extending a judgment from litigation that has already ended.

In re Koshinski (No. 26-1073) — United States Bankruptcy Appellate Panel of the Ninth Circuit, argued September 10, 2026.

Sources

Court-original argument audio — Ninth Circuit Bankruptcy Appellate Panel:https://cdn.ca9.uscourts.gov/datastore/media/2026/09/10/26-1073.mp3

Argument date and case — official recording index:https://www.ca9.uscourts.gov/cases/streams-videos/archive?case=26-1073&hearingDate=2026-09-10

Case facts and procedural history — BAP memorandum, September 17, 2026:https://cdn.ca9.uscourts.gov/datastore/bap/2026/09/17/26-1073.pdf

Revised Nevada Emergency Directive 009 — official signed attachment:https://dir.nv.gov/uploadedFiles/dir.nv.gov/content/WCS/Features/Signed%20WCS%20and%20Dec%20of%20Emergency%20directive%204-2-20.docx.pdf

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