The Court held that, as held in In re Witt, 113 F.3d 508 (4th Cir. 1997), the term "real property" in 11 U.S.C. § 1322(b)(2) includes mobile homes, despite mobile home being personal property under state tax law (Va. Code § 58.13503(6)).  Therefore, the Court held that debtors were prohibited from modifying (and in particular, bifurcating) a secured creditor's claim arising from a lien on the debtors' mobile home.

Reversed by Ennis v. Green Tree Servicing, LLC (In re Ennis), 558 F.3d 343 (4th Cir. 2009).