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§ 523(a)(2)(B)

Doyle v. Weischedel (In re Weischedel)

Ruling
Debt based on debtor's authorized use of creditor's credit card was dischargeable.
Issue(s)
Was debt incurred by debtor's authorized use of creditor's credit card nondischargeable .

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Consumer opinion summary, case decided on September 27, 2013 , LexisNexis #1013-117

Lubbock Natl Bank v. Wallace (In re Wallace)

Ruling
False financial statements rendered debt nondischargeable as against debtor but not against debtor spouse absent evidence of intent to deceive.
Issue(s)
Were false financial statements prepared by debtor, signed by debtor and spouse and relied upon by creditor grounds for denial of discharge .

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Consumer opinion summary, case decided on September 26, 2013 , LexisNexis #1013-118

JTWO LLC v. St. Hilaire (In re St. Hilaire)

Ruling
Business plan was not a statement of financial condition that could lead to nondischargeability.
Issue(s)
Was business plan a statement of financial condition that would result in nondischargeable debt if fraudulent.

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Consumer opinion summary, case decided on September 24, 2013 , LexisNexis #1213-016

Toye v. ODonnell (In re ODonnell)

Ruling
Debt was nondischargeable where personal financial statement was made with intent to deceive.
Issue(s)
Was materially false financial statement grounds for nondischargeable debt?

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on August 26, 2013 , LexisNexis #0913-084

Financial Servs. Vehicle Trust v. Barlaam (In re Barlaam)

Ruling
Car lease debt was nondischargeable due to misrepresentation of income on which creditor relied.

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Consumer opinion summary, case decided on July 31, 2013 , LexisNexis #0813-086

Eldredge v. Crusberg (In re Crusberg)

Ruling
Immaterial discrepancy in cash flow representation to creditor was not grounds for nondischargeability.
Procedural posture

Creditor filed an amended complaint against chapter 7 debtor objecting to the discharge of a debt pursuant to 11 U.S.C.S. § 523(a)(2)(B).

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Consumer opinion summary, case decided on July 17, 2013 , LexisNexis #0813-018

Pazdzierz v. First Am. Title Ins. Co. (In re Pazdzierz)

Ruling
Debt assigned postpetition for consideration was nondischargeable since the debtor's false representation occurred when the debt was incurred.
Procedural posture

Appellee assignee sought review in the United States District Court for the Eastern District of Michigan at Detroit of a bankruptcy court's decision that it could not pursue an action under 11 U.S.C.S. § 523(a)(2)(B) to have appellant debtor's debt declared non-dischargeable. The district court reversed the bankruptcy court, and the debtor sought further review.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on June 10, 2013 , LexisNexis #0713-015

Harris Trust & Savings Bank v. Gunsteen (In re Gunsteen)

Ruling
Financial statement listing transferred asset did not render debt nondischargeable where creditor did not establish debtor had made the entry.
Procedural posture

Plaintiff bank sued defendant debtor on a claim that her obligation to the bank on a personal guaranty of a loan made to a business that she co-owned was nondischargeable per 11 U.S.C.S. § 523(a)(2)(B) on the ground that the loan had been obtained or renewed by fraud, false representation, false pretenses, and materially false writings including a 2009 financial statement.

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Consumer opinion summary, case decided on February 08, 2013 , LexisNexis #0313-048

Heritage Pac. Fin. LLC v. Machuca (In re Machuca)

Ruling
Award of debtor's attorneys' fees for obtaining summary judgment in nondischargeability proceeding affirmed.
Procedural posture

Creditor sought review of a decision from the United States Bankruptcy Court for the Northern District of California, which awarded attorneys' fees to appellee debtor under 11 U.S.C.S. § 523(d) after granting summary judgment in favor of the debtor on the creditor's action seeking a determination of nondischargeability under 11 U.S.C.S. § 523(a)(2)(B).

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on December 14, 2012 , LexisNexis #0113-115

Lawyers Title Ins. Co. v. Chesson (In re Chesson)

Ruling
Claim under state unfair trade practices law was nondischargeable.
Procedural posture

Plaintiff insurer filed a complaint against defendant chapter 7 debtor, alleging a claim based upon common law fraud on the part of the debtor and a claim for unfair and deceptive trade practices under the Unfair and Deceptive Trade Practices Act (UDTPA), N.C. Gen. Stat. § 75-1.1 et seq., and seeking a determination that the damages recoverable pursuant to these claims were nondischargeable pursuant to 11 U.S.C.S. § 523(a)(2)(B).

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Consumer opinion summary, case decided on October 09, 2012 , LexisNexis #1112-015