In Crawford v. Franklin Credit Management Corp., — F.3d —-, 2014 WL 3377175 (2d Cir. 2014), the Court of Appeals for the Second Circuit held that that a Plaintiff who had filed Chapter 13 bankruptcy lost standing when she filed the Petition, but regained standing when she dismissed the Petition.

We conclude that Crawford has standing to pursue her present claims because her 2006 Petition was dismissed. Although the district court stated that Crawford lacked standing because “unscheduled assets can only re-vest in the debtor by the operation of law,” Crawford I, 2011 WL 1118584, at *14, we are persuaded that, because Crawford’s 2006 bankruptcy proceeding was dismissed, all of Crawford’s assets were indeed revested in her by operation of law. Section 349 of the Code provides, with an exception not relevant here, that unless the bankruptcy court for cause orders otherwise, “a dismissal of a case … revests the property of the estate in the entity in which such property was vested immediately before the commencement of the case,” 11 U.S.C. § 349(b)(3) (emphases added). Thus, if the debtor owned the property prior to the commencement of the bankruptcy case, a dismissal returns that property to the debtor. The district court viewed § 349 as overridden by § 554 of the Code, titled “Abandonment of property of the estate.” That section provides that after “notice and a hearing,” the trustee may “abandon any property of the estate that is burdensome to the estate or that is of inconsequential value and benefit to the estate .” 11 U.S.C. § 554(a) (without court order); id. § 554(b) (by court order). Subsection (c) of § 554 provides further that, unless the court orders otherwise, “any property scheduled under section 521(a)(1) of this title not otherwise administered at the time of the closing of a case is abandoned to the debtor and administered for purposes of section 350 of this title,” id. § 554(c) (emphases added); and subsection (d), on which the district court relied, provides that “property of the estate that is not abandoned under this section and that is not administered in the case remains property of the estate,” id. § 554(d) (emphases added). We cannot view § 554(d) as overriding § 349. As noted above, § 541(a)(1) provides that the debtor’s assets become property of the estate “as of the commencement” of the bankruptcy case; this applies whether or not the assets are listed in the required § 521(a)(1) schedule—a schedule that can be filed after the commencement of the case, see Fed. R. Bankr.P. 1007(c). The provision in § 349 for the revesting of assets is similarly broad: It makes no distinction between those that were listed in the debtor’s schedule of assets and those that were not; what is revested in the immediately-pre-petition owner or owners is “the property of the estate.” 11 U.S.C. § 349(b)(3). The legislative history makes clear that Congress intended that a dismissal would undo the bankruptcy case:  Subsection (b) specifies that the dismissal [ inter alia ] revests the property of the estate in the entity in which the property was vested at the commencement of the case…. The basic purpose of the subsection is to undo the bankruptcy case, as far as practicable, and to restore all property rights to the position in which they were found at the commencement of the case.  H.R.Rep. No. 95–595, at 338 (1977), reprinted in 1978 U.S.C.C .A.N. 5963, 6294; see A. Resnick & H. Sommer, 8 Collier on Bankruptcy ¶ 1307.09 (16th ed. rev.2013). Since the dismissal undoes the bankruptcy case, there is, upon dismissal, no longer any bankruptcy estate; and hence, there is no longer any property of the estate. See, e.g., SEC v. Great White Marine & Recreation, Inc., 428 F.3d 553, 556 (5th Cir.2005) (“Without a bankruptcy estate, there can be no property of a bankruptcy estate. See 11 U.S.C. § 349(b)(3) (a dismissal ‘revests the property of the estate in the entity in which such property was vested immediately before the commencement of the case under this title’).”); Martir Lugo v. de Jesus Saez, 721 F.2d 848, 851 (1st Cir.1983) ( “It seems self evident that there is no ‘estate’ and hence no ‘property of the estate’ unless there is an existing petition.”) As there no longer remains any “property of the estate” after a case has been dismissed, § 554 has no applicability after a dismissal. Thus, although subsections (c) and (d) of § 554 prescribe different treatments for assets at the time a bankruptcy case is “closed,” depending on whether they were or were not listed in a § 521(a)(1) schedule, the dismissal of the case under § 349, automatically revesting all of the property of the estate in its prior owners, means that there are no assets remaining to be abandoned or administered. . . .   In sum, when Crawford’s First Bankruptcy case was dismissed, the property of the bankruptcy estate revested in her by operation of law. To the extent that the district court declined to apply § 349 on the basis that the equities did not favor Crawford, that rationale bespeaks estoppel rather than lack of standing. We conclude that, by application of § 349, Crawford has standing to pursue her present claims.