523

11th Circuit Jul 14, 2021

General Default Judgment Didn’t Satisfy Requirements of Issue Preclusion, Circuit Says

If the complaint was properly plead, a general default judgment might invoke issue preclusion to bar discharge of a debt.
2nd Circuit Jul 15, 2021

All Private Student Loans Are Not Excepted from Discharge, Second Circuit Holds

No circuit split: The Second Circuit agrees with the Fifth and Tenth Circuits that only a subset of private student loans is automatically nondischargeable.