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§ 523

Schlomer, In re--Fanale v. Schlomer

Ruling
Amended complaint in nondischargeability proceeding related back to the original complaint as the new claim arose out of the same conduct, transaction, or occurrence. (Bankr. W.D. Tex.)
Issue(s)
Exceptions to Discharge; Automatic Discharge of Certain Debts Absent Creditor Objection.

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Consumer opinion summary, case decided on June 27, 2025 , LexisNexis #0825-087

Catanzarite, In re--Rewak v. Catanzarite

Ruling
Collateral estoppel did not apply to false representation and false pretenses issues, which were not actually and directly litigated in state court case. (Bankr. N.D. Ohio)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Fraud; False Pretenses, False Representations or Actual Fraud.

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Consumer opinion summary, case decided on June 18, 2025 , LexisNexis #0825-086

Burroughs, In re

Ruling
Court granted summary judgment on liability for the attorney's fees and costs awarded in the default judgment as a sanction for discovery fraud in nondischargeability proceeding. (Bankr. W.D. Ark.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted.

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Consumer opinion summary, case decided on June 18, 2025 , LexisNexis #0825-085

Norton, In re

Ruling
Court discharged debt as debtor’s partial repayments showed no intent to defraud. (Bankr. E.D. Mich.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Fraud; False Pretenses, False Representations or Actual Fraud.

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Consumer opinion summary, case decided on June 13, 2025 , LexisNexis #0825-064

Smith, In re--Keasler v. Smith

Ruling
Court excepted debt from discharge as debtor made false representations with intent to deceive. (Bankr. D. Kan.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted.

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Consumer opinion summary, case decided on June 11, 2025 , LexisNexis #0825-063

Simmons, In re--Simmons v. Simmons

Ruling
Debtor’s owelty note arising from divorce decree held nondischargeable as a domestic support obligation. (Bankr. E.D. Tex.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Domestic Support Obligations.

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Consumer opinion summary, case decided on June 09, 2025 , LexisNexis #0825-065

Wolfe, In re--Impact Images, Inc. v. Wolfe

Ruling
State court's findings of willful and malicious misappropriation of trade secrets had preclusive effect in nondischargeability proceeding. (Bankr. E D. Tenn.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Willful and Malicious Injury to Another Entity or Property of Another Entity.

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Commercial opinion summary, case decided on May 21, 2025 , LexisNexis #0725-090

Mendoza, In re--Mendoza v. Franchise Tax Bd.

Ruling
State franchise tax board’s assessments, which debtor did not timely challenge, were nondischargeable and liens securing the debt were enforceable. (Bankr. E.D. Cal.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Taxes; Late or Unfiled Return.

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Consumer opinion summary, case decided on May 21, 2025 , LexisNexis #0725-088

Adair, In re--Adair v. Stutsman Constr., L.L.C.

Ruling
Unclean hands defense to nondischargeability was improperly precluded as it was not litigated in state court default judgment proceeding. (5th Cir.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Willful and Malicious Injury to Another Entity or Property of Another Entity.

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Consumer opinion summary, case decided on May 20, 2025 , LexisNexis #0725-089

Garcia, In re--Garcia v. United States Dep't of Educ.

Ruling
Discharge of student loan debt was denied because debtor could maintain minimal living standard, lacked evidence of long-term hardship, and failed to show good faith repayment efforts. (Bankr. W.D. Tex.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Educational Loans.

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Consumer opinion summary, case decided on May 16, 2025 , LexisNexis #0725-063