Projecting the Impact of Lanning and Ransom: Calculating "Projected Disposable Income" in Chapter 13 Repayment Plans

In 2005, Congress amended the United States Bankruptcy Code (the "Code") through the Bankruptcy Abuse Prevention and Consumer Protection Act ("BAPCPA"). In part, these amendments required a formulaic calculation of the "projected disposable income" a chapter 13 debtor must pay to unsecured creditors, which is based on the debtor's prebankruptcy income and allowed expenditures. In consecutive terms, the United States Supreme Court considered the effect of changes to a debtor's income and then expenses in calculating a debtor's projected disposable income within a chapter 13 bankruptcy case.