Discharge/Dischargeability

11th Circuit Sep 29, 2020

Eleventh Circuit Reads Husky Narrowly, Perhaps Too Narrowly

Reading Husky narrowly, the Eleventh Circuit requires that fraud occur before a debt arises to make the debt nondischargeable under Section 523(a)(2)(A).
3rd Circuit New Jersey Sep 28, 2020

Repaying Salary After Arrest Isn’t Compensation for Loss and Isn’t Dischargeable

An obligation can be penal in nature, and thus nondischargeable, even though it’s measured by pecuniary loss.

Student Loan Servicer Sanctioned $378,000 for Civil Contempt by New York Judge

Bankruptcy Judge Martin Glenn imposed civil contempt sanctions for ignoring court orders over five years.
10th Circuit Aug 31, 2020

Not All Student Loans Are Nondischargeable, Tenth Circuit Holds

Tenth Circuit joins the Fifth Circuit by holding that student loans are not ‘educational benefits’ under Section 523(a)(8)(A)(ii).

Claims Discharged in Chapter 7 Revive If the Case Is Converted to Chapter 13

Courts are split over the effect on claims discharged in chapter 7 if the debtor converts the case to chapter 13.
9th Circuit Aug 3, 2020

Ninth Circuit Says Assumption Under Section 365(p) Doesn’t Also Require Reaffirmation

Lease assumption is binding even if the debtor doesn’t follow the procedural requirements of Section 365(p).

Creditor Socked with $41,000 in Sanctions for Filing Trumped-Up Criminal Charges

Bankruptcy Judge Warren makes sure the sanctions won’t be dischargeable if the offending creditor files his own bankruptcy.