the debtor must additionally allege conduct amounting to an independent tort (for example, conversion). Oakland Ridge Homeowners Ass’n v. Braverman (In re Braverman), 463 B.R. 115, 119 (Bankr. N.D. Ill. 2011). See also Wish Acquisition, LLC v. Salvino (In re Salvino), 373 B.R. 578, 589-91 (Bankr. N.D. Ill 2007), aff’d, No. 07 C 4756, 2008 WL 182241 (N.D. Ill. 2008). The elements of what constitutes an independent tort are determined by non-bankruptcy law. Sloan appears to argue that Allen’s breach of contract was an independent tort of conversion because Sloan’s equity interest was a lien on the Property. No lien was created via a deed of trust, thus casting doubt that there was a conversion of Sloan’s property. See IBA, Inc. v. Hoyt (In re Hoyt), 326 B.R. 13, 20 (Bankr. W.D.N.Y. 2005) (<HOLDING>). As discussed already, Sloan did not
holding that in order to prevail on a malicious prosecution claim under  1983 a plaintiff must establish among other things the absence of probable cause for the initiation of the proceedings against her holding security interest in insurance premiums perfected by creation of security interest holding despite contrary authority that husband debtor with a mere possessoiy interest was not entitled to claim a homestead exemption and stating it is a fundamental tenet of the law of exemptions that the debtor must have an ownership interest in the property before an exemption may be claimed a long line of illinois cases has required that a debtor have title or some ownership interest in property in order to claim a homestead exemption other courts deciding the issue under the federal exemption scheme have held that the key word is interest and that an interest in real property up to a specified amount implies a monetary interest more than just one spouses right to reside with the other holding an auctioneer liable for conversion when sales violated an unperfected security interest holding that because iba retained no security interest or other ownership interest in the dairy supplies sold to dairy andor hoyt it cannot prevail on an alleged willful and malicious cause of action for conversion