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64 Since the decline in home prices began in late 2006 and continuing in the years since, the industry has seen a steep increase in borrower attempts to strip down or even completely strip off liens in bankruptcy in cases where the amount of the liens exceed the value of the property. Because of the historical protections afforded residential mortgage holders in bankruptcy, this activity has been restricted primarily to non-residential mortgages or mortgages which are entirely unsecured (junior mortgages on property where the value of the property is less than the amount owed senior mortgages) and for the most part, restricted to Chapter 13 and Chapter 11 proceedings. However, in some jurisdictions, notably those within the Eleventh Circuit (Alabama, Florida, and Georgia), the practice spread to Chapter 7 proceedings. In 2012 the U.S. Court of Appeals for the Eleventh Circuit affirmed lower court decisions which permitted the stripping off of wholly unsecured liens in Chapter 7.1 is decision precipitated thousands of new lien stripping cases in the Eleventh Circuit. In light of the split in authority between the Eleventh Circuit and other jurisdictions and the significant economic impact of this Eleventh Circuit's decision, the U.S. Supreme Court finally tackled the issue in Bank of America v. Caulkett2. e court issued its opinion on June 1, 2015, holding that the Debtor in a Chapter 7 proceeding cannot void a junior lien even if the debt owed a senior lien exceeds the value of the collateral. BACKGROUND Generally, the bankruptcy code provides that a creditor whose claim is secured by property of the bankruptcy estate has an allowed secured claim only to the extent that the value of the property supports that claim. In other words, if the debt exceeds the value of the property, that portion of the debt which exceeds the value of the property is unsecured.3 e code further provides that to the extent such claim is not an allowed secured claim, the lien is void.4 In 1989, the U.S. Court of Appeals for the Eleventh Circuit held that pursuant to these provisions of the bankruptcy code, the debtor in Chapter 7 proceeding could completely avoid or "strip-off" a junior mortgage where the balance owed on senior liens were greater than the value of the property.5 e court reasoned that if there is no actual value in the property to support a mortgage lien, the mortgage is unsecured under bankruptcy law and thus the lien can be avoided even if it's valid under state law. e U.S. Supreme Court seemed to reject this analysis in 1992, when it addressed a similar issue in the Dewsnup case.6 In that case, the issue was whether a Chapter 7 debtor could F R O M T H E B E N C H / B E R T O N J . " B . J . " M A L E Y The Supreme Court Tackles Lien Stripping in Chapter 7 Bankruptcies. STRIPPING OFF