Cramer v. State Bar of Michigan

How later courts describe this case

• noting that forum shopping is discouraged
• “its purpose was to cover cases where an expenditure of the estate’s funds increases the value of the collateral”
• the form of the action taken to perfect is not as important as its substantive thrust-diligent action by the mortgagee which demonstrates that he would probably have obtained the rents had the bankruptcy not intervened
• Butner emerged "unscathed by the new Bankruptcy Code”