October 3, 2017 Previously Listing Property as a Principal Residence Didn’t Preclude a Later Cramdown Limited knowledge of English and ‘nuances’ in legal terms saved debtor from a fatal admission. 2nd Circuit , New York , New York Eastern District , February 20, 2017 Constructive Trust Theory Fails Without Showing Unjust Enrichment Parents who benefitted from son’s secret ownership couldn’t claim title. 2nd Circuit , New York , New York Eastern District ,