PENNSYLVANIA COURT IMPOSES A NATIONAL BAN ON SERIAL BANKRUPTCY FILER PREVENTING DEBTOR FROM FILING ANY TYPE OF BANKRUPTCY UNTIL 2036
Earlier this month a bankruptcy judge out of Pennsylvania’s Eastern District entered an order against debtor Tarani Johnson preventing her from filing any bankruptcy case in any bankruptcy court throughout the nation until 2036. In re: Tarani A. Johnson, Bky No 26-10372 (ED Penn. October 19, 2026). The court issued a 27-page opinion after the bankruptcy trustee and several creditors moved to dismiss the latest of seven bankruptcy petitions asking that Johnson be banned for life from filing any further petitions due to the “serial” nature of her filings and her “systematic abuses of the bankruptcy system.”iJohnson responded by voluntarily moving to dismiss her chapter 13 petition as of right pursuant to 11 U.S.C. § 1307(b).ii
The Court noted that Johnson sought dismissal of her case after seeking twelve emergency hearings, “several multi-hour trial dispositions spanning six months,” and ostensibly in response to a 438-page motion to dismiss filed by the trustee and several creditors. The Court explained that Johnson repeatedly sought relief “in the longest possible stretches to maximize the benefit of bankruptcy protection without any of its burdens.”iii Although entering a dismissal order, the Court retained jurisdiction to “attach conditions or impose a filing bar to the dismissal.”iv
At a subsequent hearing, the Court considered each of Johnson’s seven filings and determined that she “failed eligibility” in all of her chapter 13 cases.v To be eligible to “prosecute a chapter 13 case” Johnson was required to have “regular income” defined as stable and sufficient to pay her expenses and chapter 13 plan payments.vi Although the debtor’s income source was not dispositive on the issue of stability, the Court noted that Johnson reported being employed as a medical doctor in her 2010 filing, self-employed in both her 2011 and 2018 filings, and employed as a minister in her 2026 filing all with varying incomes.vii The Court concluded Johnson’s own filings confirmed her income was less than her expenses and that her debts exceeded the statutory thresholds permitted under 11 U.S.C. § 109(e).viii For this reason, the Court concluded that Johnson was no longer entitled to a presumption of eligibility in any future chapter 13 filing.ix
Throughout its opinion, the Court referred to the bargain between creditors and debtors noting that Johnson always reaped the benefit of the statutorily imposed stay and “breathing spell to reorganize her affairs” while failing to keep her end of the bargain which was to repay her debts.x The strategically timed bankruptcy filings left creditors without compensation and without the ability to pursue legal remedies which were “forestalled” by repeated bankruptcy stays.xi Over Johnson’s “16- year filing history” the Court noted she made payments to the trustee totaling $18,567; however, 82% of that was returned to her due to dismissals or conversions (from chapter 13 to chapter 7).xii After seven bankruptcy petitions Johnson had not made a single payment to a creditor despite reaping all the rewards of the “chapter 13 bargain.”
Acknowledging a ban on future filings to be “an extreme remedy,” the Court still surmised it was justified given the substantial court and trustee resources expended on Johnson’s frivolous filings. xiii The Court reasoned the ban would help to control the Court’s docket and to protect the integrity of the bankruptcy system. Further, to avoid “venue manipulation” and “forum shopping” which appeared likely based on Johnson’s filing history, the Court found a nationwide ban rather than a court specific ban to be appropriate.xiv Relatedly, the Court refused to impose a lifetime ban on
future filings as requested by the trustee and creditors finding it “to be the antithesis of ‘narrowly tailored” relief the law required.xv
Not surprisingly, the Court did not eliminate all of Johnson’s access to the bankruptcy courts. Provided Johnson could demonstrate a “sincere need” and a good faith intention to hold up her side of the chapter 13 bargain, Johnson could seek permission from the Court via a motion for leave to petition for bankruptcy protection before 2036.xvi The Court declined the creditor’s request for additional sanctions finding it lacked jurisdiction to impose any other sanctions after entry of the dismissal orders.xvii
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Earlier this month a bankruptcy judge out of Pennsylvania’s Eastern District entered an order against debtor Tarani Johnson preventing her from filing any bankruptcy case in any bankruptcy court throughout the nation until 2036. In re: Tarani A. Johnson, Bky No 26-10372 (ED Penn. October 19, 2026). The court issued a 27-page opinion after the bankruptcy trustee and several creditors moved to dismiss the latest of seven bankruptcy petitions asking that Johnson be banned for life from filing any further petitions due to the “serial” nature of her filings and her “systematic abuses of the bankruptcy system.” Johnson responded by voluntarily moving to dismiss her chapter 13 petition as a matter of right.
Throughout its opinion the Court referred to the bargain between creditors and debtors noting that Johnson always reaped the benefit of the statutorily imposed stay and “breathing spell to reorganize her affairs” while failing to keep her end of the bargain which was to repay her debts. The strategically timed bankruptcy filings left creditors without compensation and without the ability to pursue legal remedies which were “forestalled” by repeated bankruptcy stays. After seven bankruptcy petitions Johnson had not made a single payment to a creditor despite reaping all the rewards of the “chapter 13 bargain.”
Acknowledging a ban on future filings to be “an extreme remedy,” the Court still surmised it was justified given the substantial court and trustee resources expended on Johnson’s frivolous filings. The Court reasoned the ban would help the Court to control its docket and protect the integrity of the bankruptcy system. Further, to avoid “venue manipulation” and “forum shopping” which appeared likely based on Johnson’s filing history, the Court found a nationwide ban to be appropriate.
ii In re: Johnson, at 2. Future references are to this citation unless indicated otherwise. iii In re: Johnson, at 7, 24.
iv In re: Johnson, at 3.
vIn re: Johnson, at 11-14.
vi In re: Johnson, at 11-12.
vii In re: Johnson, at 11, 12.
viii The maximum permissible secured debt (for 2010-2025) was about $1 million to $1.5 million and maximum unsecured debt during the same time period was $360,000-$526,000. In re: Johnson, at 14, n10; 11 U.S.C. § 109(e).
ix In re: Johnson, at 14.
xIn re: Johnson, at 1, 10.
xi In re: Johnson, at 1.
xii In re: Johnson, at 17. Future references are to this citation unless indicated otherwise. xiii In re: Johnson, at 1-2. Future references are to this citation unless indicated otherwise. xiv In re: Johnson, at 18-21.
xv In re: Johnson, at 24.
xvi In re: Johnson, at 22, 25.
xvii In re: Johnson, at 26.
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