Consumer Bankruptcy Law and Practice: 11.2.1.2 Limitations on Claim Bifurcation in Chapter 7
Unfortunately, the Supreme Court somewhat limited the application of the allowed secured claim concept in Dewsnup v. Timm.10 There, despite clear statutory language in Code section 506(d) stating that a lien securing a claim that is not an allowed secured claim is void,11 the Court held that a chapter 7 debtor could not have a lien declared void on the basis of that language, even though the lien did not secure a claim that was an allowed secured claim under section 506(a).