Third Circuit disposition — 252276np-pdf

NOT PRECEDENTIAL
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
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No. 25-2276
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IN RE: REZA FARZAN,
Appellant
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On Appeal from the United States District Court
for the District of New Jersey
(D.C. Civil Action No. 3:24-cv-09116)
District Judge: Honorable Robert Kirsch
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Submitted Pursuant to Third Circuit LAR 34.1(a)
June 11, 2026
Before: BIBAS, CHUNG, and BOVE, Circuit Judges
(Opinion filed: July 8, 2026)
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OPINION*
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PER CURIAM
Reza Farzan appeals pro se from the District Court’s order affirming the
Bankruptcy Court’s dismissal of his Chapter 13 petition and denying other relief. We
will affirm.
* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not
constitute binding precedent.

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2
This appeal is the latest in a series of proceedings relating to the foreclosure of
Farzan’s New Jersey home, which has been the subject of a final state-court judgment
since September 2019. Farzan did not appeal that judgment. See In re Farzan, C.A. No.
21-1334, 2021 WL 4075750, at *1 (3d Cir. Sept. 8, 2021) (per curiam). Nor has he
agreed to vacate the property. Instead, he filed more than a dozen federal lawsuits in the
ensuing years to forestall his eviction. He also petitioned for bankruptcy on three
separate occasions, most recently in September 2023. The Bankruptcy Court dismissed
that petition in April 2024 upon finding that Farzan filed it in bad faith; the dismissal
order barred him from filing another Chapter 13 petition for one year. Farzan
unsuccessfully sought reconsideration and “multiple reliefs” and then appealed to the
United States District Court for the District of New Jersey. The District Court denied
several of Farzan’s motions on the way to denying his appeal and affirming the
Bankruptcy Court’s orders. He appeals those rulings and moves to strike the appearance
of Friedman Vartolo LLP’s counsel on the grounds that the FDCPA or the Americans
with Disabilities Act prohibits counsel from representing his own employer or its debt-
collector client, Shellpoint Mortgage Servicing (Appellees both), in this matter.
We have jurisdiction under 28 U.S.C. §§ 158(d) and 1291. We review the District
Court’s decision de novo because it sat as an appellate court reviewing the Bankruptcy
Court’s order. In re Continental Airlines, 125 F.3d 120, 128 (3d Cir. 1997). Dismissals
of bad-faith Chapter 13 petitions are subject to an abuse-of-discretion standard. See In re
LTL Mgmt., LLC, 64 F.4th 84, 99 (3d Cir. 2023).

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3
We see no error or abuse of discretion in the dismissal of Farzan’s bankruptcy
petition or the resolution of his appeal and ancillary motions. “[L]ack of good faith in
filing [a Chapter 13 petition] is sufficient cause for dismissal under [11 U.S.C.
§] 1307(c).” In re Lilley, 91 F.3d 491, 496 (3d Cir. 1996). “Bankruptcy Courts may
reasonably find that bad faith exists where the purpose of the bankruptcy filing is to
defeat state court litigation without a reorganization purpose.” In re Myers, 491 F.3d
120, 125 (3d Cir. 2007) (citation and internal quotation marks omitted). Petitioning for
bankruptcy to thwart foreclosure proceedings or judgments is an emblematic act of bad
faith. See In re Casse, 198 F.3d 327, 332-33 (2d Cir. 1999). Farzan’s quixotic litigation
strategy over the past decade provides ample reason to believe that he initiated these
bankruptcy proceedings simply to frustrate the execution of the final judgment of
foreclosure entered by the Superior Court of New Jersey nearly seven years ago. And
because dismissal was appropriate under the circumstances, his other challenges to the
Bankruptcy or District Courts’ adverse rulings on his miscellaneous motions are
unavailing.
Accordingly, we will affirm the judgment of the District Court.1
1 Farzan’s motion to strike is denied because he has not demonstrated how
counsel’s representation presents a conflict of interest.

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