5010-1(b):  REOPEN A CLOSED CASE: To File Certificate of Debtor Education

UPDATED MAY 2025

A bankruptcy case can be closed without entry of discharge if a debtor has not filed specific forms required to obtain a discharge.  Often the reason is the debtor did not file a certificate of completion of a course in financial management.  EFFECTIVE DECEMBER 1, 2024, proof of completion is made by filing a Certificate of Debtor Education.  The Certificate is obtained from the approved provider of the course.  The old form was "Official Form 423," which is no longer available.  

LBR 5010-1(b) allows for a ONE-STEP process to reopen the case because the only reason to reopen the case is known, which is to file forms to obtain a discharge.

• The court has a mandatory form motion.  See link below to a new LBR form motion posted May 2025
• The motion requires a filing fee.  See link below
• The debtor must file a notice of motion.  However, because only a debtor can file these forms, no additional service of the motion is required.  See LBR 9013-1(q).  The court has a form Notice of Motion for Order Without Hearing.   See link below T
• The court has a form order.  See link below to a new LBR form order posted May 2025.  Note in the order, the last sentence ends with a colon mark.  This is the place where an attorney can identify the limitations to representation of a client.  If there is no limitation, please indicate "No limitation."