What standard values a mobile home in Chapter 7 or Chapter 13?
Replacement value under 11 U.S.C. Section 506(a)(2): the price a retail merchant would charge for a home of like age and condition as of the petition date. Courts apply this retail standard, following the Supreme Court's Rash decision, and reject wholesale or auction figures when the debtor keeps the home.
What evidence do bankruptcy courts rely on for mobile home values?
The NADA Manufactured Housing Appraisal Guide is the workhorse; courts have set values largely from NADA data when competing appraisals conflict. Dealer retail quotes, VIN-specific identification, condition photos, and appraisal reports round out the record, and judges will adjust an appraiser's figure for age, condition, and comparable retail evidence.
Does the bankruptcy value include the land, delivery, or setup?
Often not. When the lender's lien covers only the home itself, courts limit the secured claim to the box value of the unit, excluding value attributable to its location, and have excluded delivery and setup costs from replacement value when the debtor retains the home. That distinction can shrink the secured claim substantially.
Why does the appraisal matter so much in a cramdown?
Because it caps the secured claim. If a debtor owes far more than the home is worth, a Chapter 13 plan can pay the appraised replacement value over the plan term while the balance is treated as unsecured, so lenders contest the valuation and its NADA inputs closely, and the exemption analysis may separately turn on fair market value.