On October 4, 2016, the Eleventh Circuit Court of Appeals ruled that chapter 7 debtors who file a statement of intention to surrender real property in bankruptcy cannot later contest a foreclosure action, and bankruptcy courts have broad power and authority to sanction violations. Failla v.

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Chief Judge Karen S. Jennemann of the United States Bankruptcy Court for. intent to surrender real property under that provision means that a debtor. 521(a )(2) and eleventh circuit precedent, the debtors were required to file a. already been discharged, the debtors refused to sign the warranty deed.

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