Filed 8/31/26 Lorenzetti v. Meer CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for
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IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

ROBERT J. LORENZETTI,

Plaintiff and Appellant, G065793

v. (Super. Ct. No. 30-2015-
00814445)
RONALD L. MEER,
OPINION
Defendant and Respondent.

Appeal from a postjudgment order of the Superior Court of
Orange County, Julianne Sartain Bancroft, Judge. Affirmed.
FBFK Law, George L. Hampton, Stephanie A. Pittaluga and
Christopher M. Kiernan for Plaintiff and Appellant.
Law Offices of Robert K. Kent and Robert K. Kent for Defendant
and Respondent.
* * *
 The underlying dispute in this case between plaintiff Robert J.
Lorenzetti and defendant Ronald L. Meer centers around payment for
business consulting services. In 2017, Lorenzetti obtained an amended
judgment for $390,609.88. Meer moved to stay enforcement against
community property assets, contending that his wife’s 2014 bankruptcy
discharge protected those assets. The trial court granted the motion, and
Lorenzetti appeals. He argues that the discharge does not apply to judgments
based on obligations that arose after the discharge.
We conclude that despite Lorenzetti’s attempts to establish
otherwise, the debt at issue arose well before the bankruptcy petition or
discharge. Accordingly, under the general rules that apply to community
property in the context of bankruptcy, the Meers’ community property is not
subject to collection. We find no error in the court’s ruling, and we therefore
affirm the postjudgment order.

STATEMENT OF FACTS
A. Background Facts
As of December 2008, Ronald Meer and his wife Jill1 owned and
resided in a Newport Beach home. The Meers were experiencing financial
difficulty and wished to sell the residence, which they listed for an asking
price of $11.6 million. The residence was encumbered by three deeds of trust
totaling over $10 million, all owed to the same bank. They were in arrears on
all three loans.
In early December 2008, Ronald asked Lorenzetti, who had
previously represented him in connection with another real estate loan, to

1 We refer to the Meers by their first names for ease of reference.

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assist him in obtaining the bank’s consent for a short sale of the residence.
Lorenzetti had experience dealing with banks both as an accountant and as
an employee of real estate developers. Ronald asked Lorenzetti to act as a
business consultant, perform necessary accounting services, assess the
likelihood of obtaining the bank’s agreement, prepare documentation to
support the request, and act as Ronald’s representative with the bank,
broker, and escrow company. On December 4, Ronald wrote an e-mail to a
bank officer introducing Lorenzetti and authorizing him to conduct
negotiations on Ronald’s behalf.
On December 8, Lorenzetti and Meer met and agreed to terms for
Lorenzetti’s representation. Ronald agreed to pay a fixed fee of $15,000 and a
5 percent “success fee” based on any savings.
Lorenzetti proceeded to represent Ronald. In March 2009, the
residence sold for $7 million via a short sale. The bank agreed to release all
the debt owed, which totaled $10,865,642, and to accept $6,568,000 through
escrow.
According to Ronald, the bank did not forgive or release the
Meers’ debts. Lorenzetti, therefore, was not entitled to the “‘success fee’” but
only the $15,000 fixed fee, which he claimed he paid.
According to Lorenzetti, however, the short sale resulted in a
savings of $4,297,642 to the Meers, and Lorenzetti and Ronald “agreed that
the success fee was earned.” Ronald agreed to pay, and Lorenzetti agreed to
accept, $215,000 in satisfaction of the remaining obligations owed to him.
Ronald agreed in writing to pay that sum through escrow. Eventually,
however, to permit escrow to close, Lorenzetti agreed to accept the “$215,000
owed to him outside of escrow.” Following the closing, Ronald did not pay any
part of this sum.

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B. Jill’s Bankruptcy Discharge
In 2011, Jill filed for bankruptcy, primarily related to medical
debts. Jill filed a list of creditors holding unsecured nonpriority claims and
listed Lorenzetti’s corporation, Strategic Business Management Inc., with a
claim for $25,000.2 Ronald asserts that both Lorenzetti and his corporation
were sent notice of Jill’s bankruptcy filing and did not take any action in the
bankruptcy proceedings. Lorenzetti does not dispute this.
On July 10, 2014, Jill received a chapter 7 discharge pursuant to
11 U.S.C. section 727.
C. Lorenzetti’s 2013 Lawsuit
In 2013, Lorenzetti filed his first complaint against the Meers for
breach of contract, services rendered, account stated, fraud, and fraudulent
conveyance. The parties reached an agreement under which Lorenzetti would
dismiss this action without prejudice and refile it no less than one and no
more than three years later. Lorenzetti agreed to assert only contract based
claims, and the Meers agreed not to assert the statute of limitations as a
defense.
D. Lorenzetti’s 2015 Lawsuit
In October 2015, Lorenzetti refiled his case against Ronald only,
asserting the facts set forth above. He pleaded three causes of action,
including breach of contract, services rendered, and account stated.

2 The fact that Jill’s listing of the amount owed was $25,000 is not

pertinent. Bankruptcy law focuses on notice to creditors and
dischargeability, not the precise listing of the amount of a debt (which would
have been at best unclear in 2011). (See, e.g., 11 U.S.C. § 523(a)(3) [debt is
nondischargeable not listed or scheduled in time to allow the creditor to
participate]; Licup v. Jefferson Avenue Temecula LLC (9th Cir. 2024) 95 F.4th
1234, 1238 [debt is “listed” if name and address of creditor is provided].) In
any event, Lorenzetti has never contested the dischargeability of the debt.

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Lorenzetti sought general damages of $215,000 plus interest and special
damages according to proof. Ronald filed a cross-complaint alleging unfair
business practices and unjust enrichment, but dismissed it several months
later.
On March 15, 2017, Lorenzetti and Ronald entered into a
settlement agreement. The settlement agreement stated it constituted a “full
settlement and compromise of this lawsuit and release and discharge of any
and all claims and causes of action . . . arising out of the events” specified in
the lawsuit. Ronald agreed to pay Lorenzetti $387,000, plus interest at the
rate of 4.5 percent, in return for release and discharge of all claims. The
agreement set forth a schedule for payments over time, and specified that
upon Ronald’s failure to make any scheduled monthly payment within the
allotted grace period, Lorenzetti would be entitled to entry of judgment for
the full settlement amount of $387,000, less principal payments already
made. The court was to retain jurisdiction to enforce the settlement pursuant
to Code of Civil Procedure section 664.6. The case was dismissed pursuant to
stipulation of the parties, with jurisdiction retained to enforce the agreement,
on March 3, 2017.
On August 1, 2017, Lorenzetti sought, ex parte, entry of
judgment following Ronald’s failure to pay. On the same date, the court
entered judgment for $386,500, which was subsequently amended to include
costs of $4,109.88, for a total judgment of $390,609.88.
There was not much activity in this case for several years.
Eventually some collection activity followed, including judgment debtor
discovery (see Lorenzetti v. Meer (Mar. 6, 2026, G064834) [nonpub. opn.]), and
a separate lawsuit filed by Lorenzetti in 2023 that we need not detail here.

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E. Ronald’s Motion to Stay Enforcement and the Court’s Order
In February 2025, Ronald filed a motion to stay enforcement of
the August 1, 2017 judgment. His motion argued that he and Jill had been
married since 1988, and from the time of Jill’s 2014 bankruptcy discharge
through the date of the motion, all of Ronald’s assets were community assets.
Because Jill’s bankruptcy discharge included debt to Lorenzetti’s corporation,
and both the corporation and Lorenzetti received proper notice, Lorenzetti
was precluded from attempting to enforce or collect with respect to Ronald’s
ownership in community property assets. While Lorenzetti could attempt to
collect Ronald’s separate property, he had none.
Lorenzetti opposed. His key argument was that the judgment
obtained following the settlement of the 2015 action was based on the 2017
settlement agreement. Lorenzetti contended that agreement was an entirely
new and separate obligation that arose after the 2011 bankruptcy petition
and 2014 discharge.
The court granted Ronald’s motion to stay enforcement of the
judgment with respect to community property assets. Lorenzetti now appeals.
DISCUSSION
I.
STANDARD OF REVIEW
This appeal presents a pure question of law. The material facts
relevant to that question of law are not disputed. Accordingly, our review is
de novo. (Roberts v. United Health Care Services, Inc. (2016) 2 Cal.App.5th
132, 149.)

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 II.
STATUTORY FRAMEWORK
“A chapter 7 bankruptcy petition creates an estate to satisfy
creditors’ claims.” (In re Brace (2020) 9 Cal.5th 903, 913.) At the time of
filing, that estate generally includes all separate and community property of
the applicant. (Ibid.) Filing a petition for bankruptcy relief operates as a
broad automatic stay, encompassing proceedings and collection attempts that
impact the property of the bankruptcy estate or attempt to collect debts
incurred prior to the petition. (11 U.S.C. § 362(a); Henderson v. White (In re
Henderson) (Bankr. D.N.M. 2016) 560 B.R. 365, 369 (Henderson).)
Once the bankruptcy court enters a chapter 7 discharge, the
discharge replaces the automatic stay. (Henderson, supra, 560 B.R. at p. 369.)
The discharge injunction prohibits actions brought to collect any discharged
debt. (Ibid.; see 11 U.S.C. § 524(a)(3).)
In community property states such as California, the spouse who
is not named on the bankruptcy petition (the nondebtor spouse) benefits from
the debtor spouse’s discharge of debts. The discharge prevents collection
efforts against community property acquired after the petition was filed.
“[C]ommunity claims are defined as claims that ‘arose before the
commencement of the case concerning the debtor for which property of the
kind specified in [§ 541(a)(2)] is liable.’” (Heilman v. Heilman (In re Heilman)
(9th Cir. B.A.P. 2010) 430 B.R. 213, 217 (Heilman).) “Property specified in
§ 541(a)(2) includes all interests of the debtor and debtor’s spouse in
community property liable for an allowable claim against the debtor and the
debtor’s spouse.” (Id. at pp. 217–218.) This holds true even for claims brought
solely against the nondebtor spouse. (Rooz v. Kimmel (In re Kimmel) (9th Cir.
B.A.P. 2007) 378 B.R. 630, 632 (Kimmel).) There are several exceptions to

7
this rule, but none of them are relevant in this case. (11 U.S.C. §§ 524(a)(3),
524(b).) Whether a particular debt is a community debt is determined by
reference to state law. (Heilman, at p. 216.)
Notice is a key part of bankruptcy proceedings. After filing a
bankruptcy petition, notice must be provided to potential claimants against
the bankruptcy estate, including holders of community claims. (11 U.S.C.
§ 342.)
III.
THE TRIAL COURT CORRECTLY DETERMINED LORENZETTI CANNOT COLLECT
COMMUNITY PROPERTY ASSETS ACQUIRED AFTER THE BANKRUPTCY
DISCHARGE
Before we dive into Lorezetti’s arguments, we clarify what is not
in dispute here. There is no dispute that the original debt incurred in 2008 is
a community debt. Jill was named as a defendant in Lorenzetti’s 2013
lawsuit, which alleged he had entered into a written agreement with “the
Meers” to renegotiate the debt on their home. “Plaintiff entered into an
agreement with the Meers and fully performed his obligations under the
agreement, but the Meers have failed and refused to pay plaintiff the amount
they agreed to pay, and have attempted to avoid their obligations to plaintiff
through fraud, including bankruptcy fraud and fraudulent conveyances.”
There is also no dispute that Lorenzetti received notice of Jill’s
bankruptcy petition, but he did not file any documents in the bankruptcy
proceeding.
Although Lorenzetti attempts to frame his argument in several
different ways, his fundamental argument that the 2017 settlement
agreement created a new debt entirely untethered to the original 2008
obligation lacks legal merit. Simply put, all of Ronald’s obligations to

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Lorenzetti arise out of the original 2008 obligation, and the unpaid judgment
is therefore subject to the rules surrounding discharge of community debts.
Lorenzetti argues the 2017 settlement agreement was a
“novation” that extinguished all prior claims and created entirely new
obligations. He spends much time discussing state law on what creates a
novation and what the intent of the parties might have been. “The question of
when a debt arises under the bankruptcy code is governed by federal law.”
(Siegel v. Federal Home Loan Mortgage Corp. (9th Cir. 1998) 143 F.3d 525,
532 (Siegel).) Accordingly, what matters here is how federal bankruptcy law
characterizes this debt, and Lorenzetti’s arguments regarding a novation and
the intent of the parties cite no federal cases on point.
The case law that is applicable here does not help Lorenzetti.
Siegel, supra, 143 F.4d. at page 533, held that an award of attorney fees
incurred after the filing of a bankruptcy petition based on a cause of action
that arose before the petition was not dischargeable.
In Siegel, supra, 143 F.3d 525, the debtor (Siegel) filed a
bankruptcy petition after his mortgagee, Freddie Mac, foreclosed on a
property Siegel owned and sued for a deficiency judgment. Freddie Mac filed
proofs of claim to which Siegel did not object. In March 1994, Freddie Mac
sought relief from the automatic stay so it could foreclose on a second
property. (Id. at p. 528.)
In April 1994, Siegel filed a lawsuit in state court against Freddie
Mac alleging breach of duties under the deeds of trust. (Siegel, supra, 143
F.3d at p. 528.) In June 1994, Siegel was granted a discharge. In October
1994, Freddie Mac removed the state court case to federal court and
prevailed on a summary judgment motion. (Ibid.) Thereafter, Freddie Mac

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sought and was granted an attorney fee award for defending against Siegel’s
claims. Siegel appealed. (Ibid.)
The Ninth Circuit held “the mere fact that Siegel obtained a
bankruptcy discharge did not eliminate the provision. That is, it cannot be
said that the whole contract merged into that judgment.” (Siegel, supra, 143
F.3d at p. 531.) A bankruptcy discharge “does not end a party’s obligation,
but merely prevents one method of collection.” (Ibid.) Thus, the attorney fee
provision in the contract was not extinguished. Rather, the Court held,
“whether Freddie Mac’s claim for attorney’s fees was discharged in
bankruptcy will depend on when the attorney’s fee debt arose.” (Id. at p. 532.)
The parties agreed that the contract was entered into prior to
discharge, and Siegel’s acts that gave rise the attorney fee award occurred
after the discharge. (Siegel, supra, 143 F.3d at p. 532.) The Court relied
heavily on Siegel’s voluntary act of starting a new course of litigation to find
that the attorney fee claim arose postdischarge. (Id. at pp. 532–533.)
“This is a case where the debtor, Siegel, had been freed from the
untoward effects of contracts he had entered into. Freddie Mac could not
pursue him further, nor could anyone else. He, however, chose to return to
the fray and to use the contract as a weapon. It is perfectly just, and within
the purposes of bankruptcy, to allow the same weapon to be used against
him.” (Siegel, supra, 143 F.3d at p. 533.)
“Siegel’s decision to pursue a whole new course of litigation made
him subject to the strictures of the attorney’s fee provision. In other words,
while his bankruptcy did protect him from the results of his past acts,
including attorney’s fees associated with those acts, it did not give him carte
blanche to go out and commence new litigation about the contract without
consequences.” (Siegel, supra, 143 F.3d at p. 534.) “Siegel thought that for

10
him this was the best of all possible worlds. He thought that he could use
bankruptcy to discharge all of his obligations under his contracts with
Freddie Mac and still personally retain all of his rights arising out of those
contracts.” (Ibid, italics added.) Based on this voluntary, postpetition action
on Siegel’s part, the Court found the award of postpetition attorney fees was
not discharged. (Ibid.)
Following Siegel, the Ninth Circuit decided Ybarra v. Boeing
N.Am., Inc. (In re Ybarra) (9th Cir. 2005) 424 F.3d 1018 (Ybarra). In Ybarra,
the debtor sued her employer in 1988 for employment-related claims. In
1991, she filed a chapter 11 bankruptcy petition. Significant litigation
followed, and eventually, the debtor’s claim against the employer was
scheduled as an exemption to what was, by then, a chapter 7 bankruptcy. The
debtor was granted a discharge in May 1998. (Id. at pp. 1020–1021.)
The employment matter returned to state court, where
ultimately, the employer prevailed on a summary judgment motion. (Ybarra,
supra, 424 F.3d at pp. 1020–1021.) In 1999, the employer obtained a fees and
costs judgment for over $450,000, and asked the bankruptcy court for
permission to enforce it. (Id. at p. 1021; see Ybarra v. Boeing N.Am., Inc. (9th
Cir. B.A.P. 2003) 295 B.R. 609, 612.) The bankruptcy court found the amount
of fees and costs incurred after the bankruptcy petition was filed,
$159,030.78, was collectible. (Ybarra, at p. 1021.)
The Ninth Circuit upheld the bankruptcy court’s findings.
(Ybarra, supra, 424 F.3d at p. 1022.) Finding the case was governed by
discharge principles, the Court noted that “A Chapter 7 bankruptcy discharge
releases the debtor from personal liability for her pre-bankruptcy debts.”
(Ibid.) Specifically, 11 U.S.C. section 727 “‘discharges the debtor from all
debts that arose before the date of the order for relief . . . .’” (Ibid.) “‘[D]ebt’”

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was defined as “‘liability on a claim’” and “‘[c]laim’” was broadly defined to
include a “‘right to payment, whether or not such right is reduced to
judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured,
disputed, undisputed, legal, equitable, secured, or unsecured.’” (Ibid.) “‘This
“broadest possible definition” of “claim” is designed to ensure that “all legal
obligations of the debtor, no matter how remote or contingent, will be able to
be dealt with in the bankruptcy case.”’” (Ibid.)
The date of the debtor’s petition, the Court stated, was December
1991. (Ybarra, supra, 424 F.3d at p. 1022.) The employer argued its claim did
not arise before that date and was therefore not discharged. (Ibid.)
The Court stated that “‘[a] claim arises, for purposes of discharge
in bankruptcy, at the time of the events giving rise to the claim. . . .’” (Ybarra,
supra, 424 F.3d at pp. 1022–1023.) The Ybarra court reached the same
conclusion as the Siegel court did. “[W]e have held that post-petition attorney
fee awards are not discharged where post-petition, the debtor voluntarily
‘pursued a whole new course of litigation,’ commenced litigation, or ‘returned
to the fray’ voluntarily. [Citation.] We have also endorsed the notion that by
voluntarily continuing to pursue litigation post-petition that had been
initiated pre-petition, a debtor may be held personally liable for attorney fees
and costs that result from that litigation.” (Ybarra, at p. 1024.)
Lorenzetti’s reliance on Ybarra, and by extension Siegel, is
misplaced. This case is not about attorney fees that were incurred after the
bankruptcy petition was filed. Nor did Ronald pursue new litigation or
“‘return to the fray’” voluntarily. He was sued by Lorenzetti in both 2013 and
2015. The 2017 settlement agreement did not appear like a bolt of lightening
from a clear blue sky. It was based on the allegations of the 2015 lawsuit,
which alleged that in 2008, Ronald incurred debt to Lorenzetti. Indeed,

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everything in this case traces back to the original 2008 debt. Whether
Lorenzetti frames his argument as one of “novation” or voluntary entry into a
postdischarge debt, the result is the same. Under bankruptcy law, the debt
arose in 2008, not 2017, and it was discharged during Jill’s bankruptcy
proceeding.
Kimmel, supra, 378 B.R. 630, is more relevant to the instant case.
In that case, William B. Rooz sued the Kimmels, a married couple, in 1991.
In 1993, the wife filed a chapter 7 petition, and she received a discharge in
1994. The 1991 case proceeded against the husband only, resulting in a
judgment against him in May 1995. Two months later, the couple entered
into a postnuptial agreement with the intent of transmuting the wife’s future
wages from community property to separate property. (Id. at p. 633.)
Ten years later, in 2005, the husband filed his own chapter 7
petition when Rooz began attempts to collect on the debt. Rooz filed an
adversary proceeding, seeking an order that the 1995 judgment was
nondischargeable. Rooz, who asserted he found out about the postnuptial
agreement during a meeting of creditors, amended his complaint to include
the wife. The bankruptcy court found the 1995 judgment was dischargeable
as to the husband and dismissed the case against the wife. (Kimmel, supra,
378 B.R. at p. 633.)
While Rooz’s appeal from the bankruptcy court’s order was
pending, he filed a new state court action against the wife, seeking to recover
a portion of her community property. He attacked the postnuptial agreement
as a fraudulent transfer. The wife reopened her bankruptcy case, removed
the state court case “to bankruptcy court, and moved for judgment on the
pleadings.” (Kimmel, supra, 378 B.R. at p. 633.)

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 The bankruptcy court granted the motion. The Court determined
that any attempt to collect the 1995 judgment from the wife’s wages,
regardless of whether they remained community property under the
postnuptial agreement, was barred by the discharge injunction set forth in 11
U.S.C. section 524(a)(3). (Alternatively, the Court found the fraudulent
transfer action was barred by the state law statute of limitations.) (Kimmel,
supra, 378 B.R. at pp. 633–634.)
On appeal, the bankruptcy appellate panel found the 1995
judgment was a community claim that was discharged in the wife’s
bankruptcy case. (Kimmel, supra, 378 B.R. at p. 640.) Rooz, the Court noted,
conceded that the discharge provisions of 11 U.S.C. section 524 protected the
wife from liability for the claims asserted in the 1991 litigation, but he
contended the community property interest in her postdischarge wages was
vulnerable to collection to satisfy the 1995 judgment. The Court rejected this
contention completely. (Kimmel, at p. 634.)
First, the Court found that Rooz was a creditor holding a
community claim in the wife’s bankruptcy. “[A] community claim, for
bankruptcy purposes, is a prepetition claim for which the Kimmels’
community property was liable, whether or not such claim had proceeded to a
judgment or otherwise was liquidated on the petition date.” (Kimmel, supra,
378 B.R. at p. 635.) This was particularly relevant in California, because
under the Family Code, “community property is exposed to claims against an
individual spouse. Cal. Fam. Code § 910(a).” (Ibid.)
Under 11 U.S.C. section 524(a)(3), however, the wife’s bankruptcy
discharge “permanently enjoined enforcement of the 1995 Judgment against
all future-acquired community property, including both her own and [the
husband’s] interests in her wages.” (Kimmel, supra, 378 B.R. at p. 635.)

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Therefore, the nondebtor spouse’s liability survives the bankruptcy, but can
only be enforced against separate property. (Id. at p. 636.) Ultimately, the
Court found that even if the wife’s wages remained community property
despite the postnuptial agreement, the husband’s interest in the community
property was immune from any attempt to collect on the 1995 judgment. (Id.
at p. 637.)
Rooz also argued that the wife’s postdischarge conduct by
entering into the postnuptial agreement created a new debt. (Kimmel, supra,
378 B.R. at p. 638.) The Court rejected this argument. First, the Court held,
the discharge was “absolute and, in light of the anti-waiver provisions of
§ 524(a), does not admit of an equitable exception that would permit it to be
waived by postdischarge conduct.” (Ibid.) Second, 11 U.S.C. section 524(a)(3)
prohibits any act “to collect or recover from” community property “that is
acquired after commencement of the case, on account of any allowable
community claim,” unless the claim has been excepted from discharge. “Thus,
it was impossible for the community property ([the wife’s] future wages) that
was transmuted into separate property to have been a source of recovery for
Rooz.” (Kimmel, at p. 639.)
Kimmel not only has more in common with this case than Siegel
or Ybarra, it also leaves a number of propositions very clear. The community
property of a nondebtor spouse acquired after a bankruptcy discharge is
uncollectable for any purpose. “[A]s one commentator has explained, ‘the
Devil himself could effectively receive a discharge in bankruptcy if he were
married to Snow White.’” (Kimmel, supra, 378 B.R. at p. 637.) The only
question here is when the debt arose, and as we have noted, the entire debt
can be unambiguously traced back to the original 2008 debt the Meers
incurred to Lorenzetti.

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 When a bankruptcy proceeding occurs, creditors must be diligent.
(Kimmel, supra, 378 B.R. at p. 637.) Lorenzetti had ample opportunity to
seek redress during Jill’s bankruptcy proceeding. After he received notice, he
could have filed a claim against the bankruptcy estate, a nondischargeability
action, or an objection to discharge. (Ibid.) He did none of these. Based on
fundamental principles and the strong protections that bankruptcy law
affords, however, he cannot now seek to collect what was a prepetition
community debt.
IV.
LORENZETTI MAY ATTEMPT TO COLLECT THE DEBT FROM RONALD’S SEPARATE
PROPERTY
Lorenzetti also argues that he “retains the right to collect from
any separate property [Ronald] may acquire and from [Ronald]’s interest in
community property.” He is half right. As we have discussed, he cannot
collect from community property acquired after the date of the petition. (11
U.S.C. 524 (a)(3).) He may attempt to collect from Ronald’s separate property,
if any. The court’s order stated as much: “The motion to stay enforcement of
the judgment with respect to community property assets is GRANTED. To
the extent that the judgment may be enforced, Lorenzetti may only seek
enforcement against [Ronald]’s separate property assets.” Judgments, as the
saying goes, last a long time. In California, they can last for 20 years. (Code
Civ. Proc. §§ 683.020, 683.120.) Should Ronald’s circumstances change, the
posture of this case may also change significantly.
Lorenzetti also contends “normal collection procedures should be
permitted to determine what assets, if any, are available for satisfaction.” We
have no order before us that limits what collection procedures may or may

16
not be used, and accordingly, it would be inappropriate for us to opine on this
subject.
Lorenzetti argues that Ronald’s arguments create “perverse
incentives” for bad behavior by nondebtor spouses and “discourage
settlements.” We cannot help with these policy arguments. Bankruptcy law,
as Lorenzetti surely knows, is federal law. His only redress for these
supposed ills lies with federal legislators, not this court.
DISPOSITION
The postjudgment order is affirmed. Ronald is entitled to his
costs on this appeal.

MOORE, J.

WE CONCUR:

MOTOIKE, P. J.

SERVINO, J.

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