April 23, 2018 Still No Universal Test for Bifurcating an Auto Loan in Chapter 13 Courts are groping to define ‘personal use’ because Congress didn’t. 6th Circuit , Tennessee , Tennessee Eastern District , May 1, 2017 Jevic Applied to Ordinary Settlements in the Midst of a Chapter 11 Case Tennessee judge says Jevic tightened rules for approval of settlements. 6th Circuit , Tennessee , Tennessee Eastern District ,