Prochnow v. Apex Properties, Inc.
United States District Court for the Central District of Illinois
467 B.R. 656 (2012)
Realtor Jeffrey Prochnow (plaintiff), working on commission for Remax (defendant), filed for Chapter 7 bankruptcy in 2009 but continued working under his existing contract, later seeking to reopen his closed bankruptcy case to claim commissions from property closings that occurred after his petition but stemmed from his earlier, pre-petition sales efforts; the bankruptcy court ruled the commissions belonged to the estate since they were earned pre-petition, and also found Prochnow judicially estopped for failing to disclose them.
Whether a future interest is part of the bankruptcy estate if the future interest was earned by services performed pre-petition by the debtor, even if the interest did not vest until post-petition.