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§ 1328(a)(4)

Dingess, In re--Olsen v. Dingess

Ruling
Debtor’s injury to mother-in-law was dischargeable as evidence did not show willful or malicious intent and default judgment lacked preclusive effect. (Bankr. D. Del.)
Issue(s)
Discharge; Full-Compliance Discharge; Restitution or Damages For Willful or Malicious Injury or Death.

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Consumer opinion summary, case decided on May 14, 2025 , LexisNexis #0725-073

Firth, In re--Medeiros v. Firth

Ruling
Malicious prosecution claim was a proper basis for relief under § 1328(a)(4). (Bankr. D.D.C.)
Issue(s)
Discharge; Full-Compliance Discharge; Restitution or Damages For Willful or

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Judge or Jurisdiction information not available
Consumer opinion summary, case decided on January 11, 2023 , LexisNexis #0323-017

Hilgartner, In re

Ruling
Debtor's objections to the creditor's claim was overruled as not barred by the parties’settlement agreement and it was not required that damages be awarded in a civil action beforea bankruptcy case was filed. (Bankr. E.D. Va.)
Issue(s)
Discharge; Full-Compliance Discharge; Restitution or Damages For Willful or

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Consumer opinion summary, case decided on August 05, 2020 , LexisNexis #0920-072

Denson, In re--Michael v. Denson

Ruling
Debt was excepted from discharge where debtor's actions caused personal injury to creditor.(Bankr. S.D. Ind.)
Issue(s)
Discharge; Full-Compliance Discharge; Restitution or Damages For Willful or

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Consumer opinion summary, case decided on March 30, 2020 , LexisNexis #0520-096

Szewc, In re--Krein v. Szewc

Ruling
Court concluded that a portion of the judgment debt was nondischargeable where creditors proved that the interference with their personal rights caused by debtors' willful or malicious conduct was substantial. (Bankr. D. Or.)
Issue(s)
Discharge; Full-Compliance Discharge; Restitution or Damages For Willful or Malicious Injury or Death.

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Consumer opinion summary, case decided on March 06, 2017 , LexisNexis #0417-055

Sales v. Bailey (In re Bailey)

Ruling
Overtime claims were not excepted from discharge as based on economic rather than personal injury.
Issue(s)
Were overtime claims of debtor's former employees nondischargeable?

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Consumer opinion summary, case decided on March 03, 2016 , LexisNexis #0316-137

Seubert v. Deluty (In re Deluty)

Ruling
Default judgment under state and city nondiscrimination laws was nondischargeable.
Issue(s)
Was state court default judgment for sexual harassment nondischargeable?

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Consumer opinion summary, case decided on October 09, 2015 , LexisNexis #1115-032

Enigami Sys. v. Baca (In re Baca)

Ruling
Nondischargeability under §1328(a)(4) was limited to natural, living individuals.
Issue(s)
Could corporate creditor claim nondischargeability of its claim for restitution or damages awarded in a civil action as a result of willful or malicious injury by the debtor pursuant to 11 U.S.C. § 1328(a)(4)?

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Consumer opinion summary, case decided on February 28, 2014 , LexisNexis #0914-063

Bailey v. Digirolamo (In re Digirolamo)

Ruling
Judgment for battery was nondischargeable.
Issue(s)
Were damages awarded in civil action for battery nondischargeable.

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Consumer opinion summary, case decided on January 17, 2014 , LexisNexis #0214-068

Dorris v. Chacon (In re Chacon)

Ruling
Relief from stay granted to allow sexual assault victim to pursue civil case against debtor who pled guilty to criminal charges.
Procedural posture

Plaintiff, a mentally disabled woman ("victim"), filed an adversary proceeding by and through her guardian, seeking a determination that claims she filed against defendant Chapter 13 debtor in a New Mexico court were nondischargeable under 11 U.S.C.S. § 1328(a)(4), an order granting relief from the automatic stay so she could proceed with an action that was filed in state court. The victim filed a motion for summary judgment.

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Consumer opinion summary, case decided on October 01, 2010 , LexisNexis #1110-064