Protection Act of 2005, S. 256, Pub.L. 109-8, 119 Stat. 23 (2005), applicable to cases filed after October 17, 2005. 27 . Stuart v. Koch (In re Koch), 109 F.3d 1285, 1286 (8th Cir.1997) (‘‘[A] Chapter 7 debtor's ability to fund a Chapter 13 plan 'is the primary factor to be considered in determining whether granting relief would be a substantial abuse.’ ”) (cited in In re Keepper, 329 B.R. 693, 696 (Bankr.W.D.Mo.2005)). Because of the amount of their unsecured debts, the Debtors here would not have qualified for Chapter 13 pursuant to § 109(e). However, although BAPCPA expressly codified Chapter 11 eligibility for individuals, individuals were eligible to be debtors under Chapter 11 when this case was filed. See Toibb v. Radloff, 501 U.S. 157, 111 S.Ct. 2197, 115 L.Ed.2d 145 (1991) (<HOLDING>). 28 . 11 U.S.C. § 707(b)(1), as applicable to
holding consumer debtors may be eligible for chapter 11 under certain circumstances holding that the plain language of  706b authorized conversion of an individual debtor to chapter 11 over his or her objection holding in a case where a chapter 11 trustee was appointed after a period during which the debt or had operated as debtor in possession that a chapter 11 trustee has two years from the date of his appointment not from the commencement of the chapter 11 case to bring avoidance actions holding that notwithstanding a debtors inability to obtain a chapter 13 discharge a debtor is nonetheless eligible to file a chapter 13 case holding that an individual debtor not engaged in business is eligible for chapter 11