In re Godley, No. 11-03953-8-RDD, 2014 Bankr. LEXIS 483 (Bankr. E.D. N.C. Feb. 5, 2014)

(Chapter 12 case in which debtor's confirmed plan in which part of creditor's secured claim to be paid from proceeds obtained by avoiding landlord's lien on 2010 corn crop; debtor sought avoidance of lien under 11 U.S.C. Sec. 543(3) (statutory landlord's lien) and 11 U.S.C. Sec. 544(a)(1) (consensual lien); court noted that SEc. 543(3) allows debtor to avoid "fixing" of statutory lien to extent lien is for rent, and that lien was "fixed" to 2010 corn crop from time it was raised until seven months prepetition (which was after crop had been harvested, sold and rent paid) when it was extinguished in full by payment under the lease; thus, no statutory lien that could be "fixed" on anything as of date petition filed and, therefore, lien could not be avoided; rent amount paid in full before lease expired; thus, consensual lien not avoidable).