IN RE: Jamaal Albert Jackson (2026)

Chapter 13

ORDER IMPOSING MONETARY SANCTION AND BARRING JAMAAL ALBERT JACKSON FROM FILING A BANKRUPTCY CASE UNDER ANY CHAPTER IN ANY DISTRICT UNTIL MAY 19, 2029

THIS MATTER came before the Court for a hearing on July 29, 2026, to consider the Order Dismissing Case and Rule to Show Cause (the “Rule to Show Cause”) entered on June 11, 2026.¹ The Rule to Show Cause ordered the automatic stay of 11 U.S.C. § 362 annulled ab initio and dismissed this case subject to the Court retaining jurisdiction to consider appropriate sanctions, including whether to find pro se Debtor Jamaal Albert Jackson (“Jackson”) in contempt. It required Jackson to pay the filing fee due for this case in full by June 25, 2026; file any response or objection by July 6, 2026; and appear at the July 29, 2026, hearing to show cause why a finding of civil contempt should not be made, why this matter should not be certified to the United States District Court for the District of South Carolina for a determination of whether to find Jackson in criminal contempt, and why further sanctions should not be imposed for filing this case in an improper venue, for repetitive filings, and for filing this case in violation of court orders. After due notice, Jackson did not respond and did not appear at the hearing.

Undisputed Facts

This is not Jackson's first bankruptcy case. On June 13, 2025, Jackson filed Case Number 25-02235 in the Eastern District of North Carolina (the “First Case”). That case was dismissed on October 15, 2025, when Jackson failed to appear at a hearing to oppose dismissal.

On September 22, 2025—while the First Case was still pending—Jackson filed Case Number 25-30985 in the Western District of North Carolina (the “Second Case”). That case was dismissed on February 11, 2026, due to Jackson's failure to file a confirmable plan and make payments to the trustee.

On January 30, 2026—while the Second Case was still pending—Jackson filed Case Number 26-00453 in the Eastern District of North Carolina (the “Third Case”). That case was dismissed with prejudice on April 14, 2026, due to Jackson's repetitive filings across different federal districts, with Jackson barred from filing another bankruptcy case in any federal district for 180 days.

On March 24, 2026—while the Third Case was still pending—Jackson filed Case Number 26-30350 in the Western District of North Carolina. That case was dismissed on April 23, 2026, due to his failure to disclose his prior case, pay the filing fee, and file all of the required documents, with Jackson barred from filing bankruptcy cases for 180 days following that order dismissing the case.

Thereafter, Jackson filed four more bankruptcy cases in violation of prior orders barring refiling, including this case, as outlined below.

On April 29, 2026, Jackson filed Case Number 26-30569 in the Western District of North Carolina, which was dismissed the same day.

On May 5, 2026, Jackson filed Case Number 26-30630 in the Western District of North Carolina. That case was dismissed the same day, with an extension of the bar against future filings from 180 days to a full year.

On May 19, 2026, Jackson filed Case Number 26-30685 in the Western District of North Carolina. That case was dismissed the same day, with an extension of the bar against future filings from one year to two years. Therefore, Jackson was barred from filing a bankruptcy case until May 19, 2028.

On June 9, 2026, Jackson filed his petition for relief under Chapter 13 of the Bankruptcy Code in this Court, including schedules and statements, through the Court's Electronic Self-Representation System.² The schedules and statements are largely blank and some of the required documents are missing. Jackson has not paid the filing fee nor filed a Certificate of Credit Counseling. In response to Part 1, Question 6 of the petition, which asks “why are you choosing this district to file for bankruptcy?” Jackson wrote “Close.” However, the petition reflects that Jackson lives in Charlotte, North Carolina, and on Part 1, Question 2 of the Statement of Financial Affairs for Individuals Filing for Bankruptcy, in response to the question “during the last 3 years, have you lived anywhere other than where you live now?” Jackson checked the box stating, “No.” Further, Jackson submitted as a means of identification a North Carolina driver's license that lists the same Charlotte, North Carolina address that is listed on his petition.³ The schedules do not list any real property located in South Carolina owned by Jackson or any creditors located here. In short, nothing in the petition, schedules, or statements reflect any connection to South Carolina sufficient to justify filing a bankruptcy case here.

In response to the question “have you filed for bankruptcy within the last 8 years?” on Part 2, Question 9 of the petition, Jackson checked the box stating, “Yes,” and listed only the Second Case. This Court's review of court records revealed the other cases listed above, and the various restrictions on filing a bankruptcy case.

On June 11, 2026, the Court entered the Rule to Show Cause at issue herein.⁴

The above facts clearly evidence Jackson's bad faith in filing this case and an attempt to circumvent and disregard the orders entered by bankruptcy courts in other districts barring him from filing a bankruptcy case by filing this case in an improper venue.

Applicable Law

Regarding venue,

a case under title 11 may be commenced in the district court for the district—(1) in which the domicile, residence, principal place of business in the United States, or principal assets in the United States, of the person or entity that is the subject of such case have been located for the one hundred and eighty days immediately preceding such commencement, or for a longer portion of such one-hundred-and-eighty-day period than the domicile, residence, or principal place of business, in the United States, or principal assets in the United States, of such person were located in any other district; or (2) in which there is pending a case under title 11 concerning such person's affiliate, general partner, or partnership.

28 U.S.C. § 1408. This case does not fit within those parameters. When a case is filed in an improper venue, the case may be dismissed. See Fed. R. Bankr. P. 1014(a)(2). Further, filing a case in an improper venue may subject the filer to sanctions under Fed. R. Bankr. P. 9011 when there is no good faith basis in fact or law to support the filing of the petition in the improper venue. See In re Niemiec, 661 B.R. 514, 519-21 (Bankr. D.S.C. 2024).

Local Rule 9011-1 provides, in pertinent part:

A debtor․shall have the duty to ascertain that no previous order, statute, or rule makes the debtor ineligible to file or bars the applicable filing of a petition in bankruptcy before this Court. The signing and filing of a petition by a debtor․will be deemed a certification to the Court that the debtor is eligible to file the petition and is not in violation of a previous order of dismissal with prejudice, statute, or rule.

SC LBR 9011-1(d).⁵ “The Court has the power to sanction litigants and their counsel under 11 U.S.C. § 105 for a blatant disregard for clear orders and rules.” In re Hair, 653 B.R. 816, 820 (Bankr. D.S.C. 2023) (citing In re Kennedy, 633 B.R. 293 (Bankr. D.S.C. 2021); 11 U.S.C. § 105(a)). Possible sanctions for violating a bar on refiling include monetary fines, ex parte dismissal of the case and annulment of the automatic stay, and extensions of the bar on refiling. See id. (citing In re Brown, No. CIV.A. 02–00089–W, 2002 WL 368443, at *1 (Bankr. D.S.C. Jan. 31, 2002)). See also In re Diaz, No. CIV.A. 01–11798–W, 2001 WL 1805999, at *1 (Bankr. D.S.C. Dec. 7, 2001) (“In instances where the clear and unambiguous order of this Court which prohibits refiling of bankruptcy is violated, this Court believes the bar to refiling should be extended․.”).

The Fourth Circuit has recognized that debtors can be barred from refiling other bankruptcy cases when there is evidence of bad faith. In re Pressley, 518 B.R. 867, 872 (Bankr. D.S.C. 2014) (citing Colonial Auto Ctr. v. Tomlin (In re Tomlin), 105 F.3d 933, 937 (4th Cir. 1997)). “The general rule is that dismissal with prejudice is warranted when there is ‘egregious behavior’ that prejudices creditors and is abusive of the bankruptcy system.” Id. (quoting In re Tomlin, 105 F.3d at 937).

In re Hair, 653 B.R. 816, 821 (Bankr. D.S.C. 2023).

Conclusion

The Court concludes that Jackson's conduct demonstrates bad faith, is egregious, has prejudiced creditors, and is abusive of the bankruptcy system. Within a little over a year, Jackson has filed eight bankruptcy cases. Three of them were filed while other bankruptcy cases were still pending, four of them were filed in violation of prior orders barring refiling, and this case (if not others as well) were filed in an improper venue. Meanwhile, Jackson's creditors have been delayed in enforcing their rights and have received little, if any, benefit from the cases. Accordingly, to prevent Jackson from further abusing the bankruptcy system, to deter other debtors from similar conduct, and to compensate for the resources expended on frivolous filings, the Court will extend the bar on refiling for an additional year and will impose a sanction in the amount of $500.00. This amount is due in addition to the filing fee for this case.

IT IS, THEREFORE, ORDERED:

1. The bar on Jamaal Albert Jackson filing another bankruptcy case is extended for an additional year from the current expiration of such bar, such that he shall be barred from filing another bankruptcy case under any Chapter of the Bankruptcy Code in any District until after May 19, 2029; and

2. Jamaal Albert Jackson shall pay a sanction in the sum of $500.00 to the U.S. Treasury via Pay.gov.6

FOOTNOTES

1.   ECF No. 12.

2.   ECF No. 1. See SC LBR 5005-4(d)(2).

3.   ECF No. 5.

4.   ECF No. 12.

5.   The Court's Local Rules are available on its website at https://www.scb.uscourts.gov/local-rules.

6.   Jackson may contact the Court for instructions regarding how to make this payment.

Chief US Bankruptcy Judge District of South Carolina