Clark v. DeVries (In re Clark), Case No. 1:13-cv-00305-EJL, 2014 U.S. Dist. LEXIS 28375 (D. Idaho Mar. 4, 2014)

(debtor appealed the bankruptcy court’s decision granting a customer’s motion to convert the debtor’s Chapter 12 to a Chapter 7 on the grounds of fraud; the bankruptcy court had found that the debtor committed fraud by entering into a contract for the sale of hay with the customer eight days after filing the Chapter 12 and without telling the creditor about the filing; in affirming the decision, the court ruled that the bankruptcy court properly applied 11 U.S.C. § 1208(d) in concluding that the debtor had committed fraud “in connection to the case”; the court also found that the bankruptcy court did not clearly err in making its factual findings; the record established that the debtor failed to inform the customer about material information).