Christopher M. Cook v. Chapter 13 Trustee

── Christopher M. Cook v. Chapter 13 Trustee ── Court: Court of Appeals for the Fourth Circuit Date: April 13, 2026 Category: General USCA4 Appeal: 25-1048 Doc: 71 Filed: 04/13/2026 Pg: 1 of 13 PUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 25-1048 In re: CHAPTER 13 TRUSTEE. ------------------------------ CHRISTOPHER M. COOK, Debtor – Appellant, v. CHAPTER 13 TRUSTEE, Trustee – Appellee. ------------------------------ NATIONAL ASSOCIATION OF CONSUMER BANKRUPTCY ATTORNEYS, NATIONAL CONSUMER BANKRUPTCY RIGHTS CENTER, Amici Supporting Appellant. Appeal from the United States District Court for the Eastern District of Virginia, at Alexandria. Michael Stefan Nachmanoff, District Judge. (1:24-cv-00288-MSN-WBP) Argued: March 18, 2026 Decided: April 13, 2026 Before GREGORY, WYNN, and BERNER, Circuit Judges. District court dismissal reversed; bankruptcy court judgment affirmed by published opinion. Judge Berner wrote the opinion, in which Judge Gregory and Judge Wynn joined. USCA4 Appeal: 25-1048 Doc: 71 Filed: 04/13/2026 Pg: 2 of 13 ARGUED: Robert S. Brandt, LAW OFFICE OF ROBERT S. BRANDT, Alexandria, Virginia, for Appellant. Richard Preston Cook, RICHARD P. COOK, PLLC, Wilmington, North Carolina, for Amici Curiae. Thomas P. Gorman, OFFICE OF THE CHAPTER 13 TRUSTEE, Alexandria, Virginia, for Appellee. ON BRIEF: Marcelo R. Michel, OFFICE OF THE CHAPTER 13 TRUSTEE, Alexandria, Virginia, for Appellee. 2 USCA4 Appeal: 25-1048 Doc: 71 Filed: 04/13/2026 Pg: 3 of 13 BERNER, Circuit Judge: This case concerns the bounds of equitable mootness, a doctrine applied only in the context of bankruptcy. When applied, the doctrine permits a court to avoid addressing the merits of a case. Equitable mootness differs significantly from Article III mootness, which concerns the court’s jurisdiction and is, therefore, not discretionary. Kiviti v. Bhatt, 80 F.4th 520, 531 n.5 (4th Cir. 2023). By contrast to this constitutional limitation on judicial authority, equitable mootness is a “pragmatic doctrine” under which a court sitting in review of a bankruptcy decision may “dismiss an appeal when ‘changes to the status quo following the order being appealed make it impractical or inequitable to unscramble the eggs.’” Id. (quoting In re Castaic Partners II, LLC, 823 F.3d 966, 968 (9th Cir. 2016)). The key inquiry with respect to equitable mootness is whether the requested relief is available as a practical matter. In other words, a court must consider whether it would be possible to grant the requested relief without undermining the structure and purpose of the bankruptcy plan. Christopher Cook filed for bankruptcy in May 2023. The bankruptcy court denied confirmation of the first plan Cook proposed, finding the plan failed to comply with statutory requirements. Over the next several months, Cook submitted two more revised plans, which the bankruptcy court declined to confirm. Finally, the bankruptcy court confirmed Cook’s fourth proposed plan. After his fourth plan was confirmed and Cook began to comply with its parameters, Cook appealed to the district court, arguing that the bankruptcy court should have confirmed his first proposed plan. The district court declined 3 USCA4 Appeal: 25-1048 Doc: 71 Filed: 04/13/2026