14 F.3d at 1500. We conclude that it does not. Courts have recognized that the act of reopening a closed bankruptcy case does not afford the parties any substantive relief. Woods, 173 F.3d at 777 (quoting DeVore v. Marshack (In re DeVore), 223 B.R. 193, 198 (9th Cir. BAP 1998), for the proposition that “[t]he reopening of a case is ‘merely a ministerial or mechanical act [that] ... has no independent legal significance and determines nothing with respect to the merits of the case.’ ”); see Cusano v. Klein, 264 F.3d 936, 948 (9th Cir.2001) (noting that order reopening closed case “ ‘lacks independent legal significance and determines nothing with respect to the merits of the case’ ”) (quoting Menk v. LaPaglia (In re Menk), 241 B.R. 896, 913 (9th Cir. BAP 1999)); Paine, 250 B.R. at 107 (<HOLDING>). Indeed, “ ‘[t]he effect of [11 U.S.C. §
holding that department does not have independent authority to impose device in absence of court order recognizing that an order reopening a closed case was simply a mechanical device that did not afford or deny the debtors any affirmative relief holding that court lacked jurisdiction on appeal from injunction because the order was simply an interpretation of an earlier order recognizing laches as an affirmative defense recognizing that a defendant may not insist on representation by an attorney he cannot afford