Case Explained: Non-Argument Calendar In re: BARBARA JOYCE REAVES SMITH Debtor. VINCE FARIDANI v. BARBARA JOYCE REAVES SMITH

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-01 Docket: 7:24-cv-00086-WLS, The eleventh-circuit affirmed the district court’s order affirming the bankruptcy court’s entry of judgment against Vince Faridani in his adversary proceeding. The court held that the district court did not abuse its discretion in resolving the appeal on procedural grounds because Faridani failed to include necessary transcripts of the bench trial and telephonic conference in the record before the district court. The court applied Federal Rule of Bankruptcy Procedure 8009(a)(1)(A), 8009(a)(4), and 8009(b)(5), which require an appellant to designate items for the record on appeal, including transcripts of oral rulings and testimony when challenging factual findings. The court reasoned that while pro se litigants are held to a less stringent standard than attorneys, they must still comply with applicable procedural rules and bear the burden of ensuring the appellate record is adequate for review. Because Faridani failed to submit the transcripts required to demonstrate that the bankruptcy court’s findings were unsupported by evidence, the district court was unable to conduct meaningful review of his arguments regarding fraud in the inducement under 11 U.S.C. § 523(a)(2)(A). The court further declined to consider new arguments or transcripts submitted for the first time to the appellate court, noting that it reviews only the evidence part of the record before the district court and will not evaluate issues never addressed by the lower court. As a result, the judgment in favor of the debtor, Barbara Joyce Reaves Smith, stands, and Faridani’s attempt to have his debt declared nondischargeable due to alleged fraud was unsuccessful. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.