In re Ross, 838 F.3d 779 (3rd Cir. 2017) – A debtor filed bankruptcy to block a foreclosure. When he sought to voluntarily dismiss the case, the bankruptcy court granted the request but also enjoined him from filing at any time in the indefinite future. The order was appealed first to the district court and then to the Third Circuit. After the debtor and his wife fell behind in their mortgage payments, the mortgagee filed a foreclosure action, obtained a default judgment and