December 9, 2016 Judge Reverses Course and Allows Reclassification of Deficiency Claim Chapter 13 debtor permitted to surrender collateral and reclassify deficiency as unsecured. 11th Circuit , Alabama , Alabama Northern District , April 26, 2016 Courts Split on Standards Justifying Hardship Discharge ‘Catastrophic event’ not required for hardship discharge. 11th Circuit , Alabama , Alabama Northern District ,