Whether the post-petition, pre-conversion increase in value of a debtor's homestead belongs to the debtor or the Chapter 7 estate

QUESTION PRESENTED Whether, when a debtor in good faith converts a bankruptcy case to Chapter 7 after confirmation of a Chapter 13 plan, the post-petition, pre-conversion increase in value of the debtor’s homestead belongs to the debtor (as the Tenth Circuit held in Rodriguez v. Barrera (In re Barrera), 22 F. 4th 1217 (10th Cir. 2022) or the Chapter 7 estate, and is therefore available for distribution to creditors (as the Ninth Circuit held below).