July 26, 2018 California Judge Won’t Allow ‘Chapter 20’ to Work Its Magic Opinion doesn’t cite contrary Ninth Circuit and BAP authority permitting ‘chapter 20.’ 9th Circuit , California , California Central District , April 7, 2017 Judge Splits with his BAP and Allows ‘Substantial Contribution’ Claim in Chapter 7 Split grows on whether ‘substantial contribution’ claims are limited to chapters 9 and 11. 9th Circuit , California , California Central District ,