In an opinion handed down on June 1, 2015, the Supreme Court of the United States ruled on the question of whether a debtor in a chapter 7 case may void a junior secured position under Section 506(d) of the Bankruptcy Code when the debt owed on a senior secured position exceeds the present value of the property. The Supreme Court answered that the debtor may not strip the junior secured position. The case is Bank of America, N.A. v. Caulkett, _ U.S. _ (2015).