Chapter 13 Plan and Res Judicata. The Second Circuit has held that a Chapter 13 bankruptcy confirmation order is res judicata with respect to the debtor's and the Trustee's post-confirmation attempt to avoid a confirmed, recorded lien on the debtor's property where the lien was claimed by the debtor at the outset of the bankruptcy proceedings and included in the plan. The decision in Celli v. First National Bank of Northern New York (In re Celli) can be found here.