In re Lavenhar 808 F.3d 794, 796 (10th Cir. Dec. 17, 2015)

This appeal arises out of a Chapter 7 bankruptcy petition where the debtor’s ex-wife filed a proof of claim in the bankruptcy proceedings for a “domestic support obligation” in the amount of nearly $350,000. The Tenth Circuit held that a judgment creditor has standing to intervene in a debtor’s state-court divorce proceedings to seek a declaration that the divorce decree underlying the ex-wife’s proof of claim was obtained by fraud on the court.