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§ 523(a)(7)

Tipsy McStumbles LLC v. Griffin (In re Griffin)

Ruling
Contempt sanction was not payable to governmental unit and was dischargeable.
Procedural posture

Creditors filed an adversary complaint for a judgment that a monetary sanction owed by defendant debtor under a contempt judgment entered by a federal district court (FDC) based on debtor's conduct in violating a preliminary injunction (PI) was nondischargeable in debtor's chapter 7 per 11 U.S.C.S. § 523(a)(7).

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Consumer opinion summary, case decided on May 10, 2013 , LexisNexis #0613-054

Wiebe v. Kansas Dept. of Labor (In re Wiebe)

Ruling
State labor department penalty that was not compensatory was excepted from discharge.
Procedural posture

Debtors filed this adversary proceeding to obtain a determination that the $123,966 penalty imposed by the Kansas Department of Labor should not be excepted from their discharge under 11 U.S.C.S. § 523(a)(7) because, as they argued, it was compensatory.

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Consumer opinion summary, case decided on January 25, 2013 , LexisNexis #0213-117

New Image Motor Sports Fin. LLC v. Jackson (In re Jackson)

Ruling
Repayment obligation that an element of criminal sanctions against debtor was nondischargeable.
Procedural posture

Judgment creditor filed a motion for summary judgment in its adversary proceeding against defendant debtors, which sought a determination that the debt purportedly owed by the debtors was excepted from discharge under 11 U.S.C.S. § 523(a)(7).

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Consumer opinion summary, case decided on December 07, 2012 , LexisNexis #0113-018

In re Styer

Ruling
Civil restitution obligation for benefit of consumers rather than government was dischargeable.
Procedural posture

After a state court entered a decision ordering defendant debtor to pay civil restitution under § 201-4.1 of the Pennsylvania Unfair Trade Practices and Consumer Protection Law, 73 Pa. Stat. Ann. § 201-4.1, plaintiff Commonwealth sought a determination that the restitution award was nondischargeable pursuant to 11 U.S.C.S. § 523(a)(2)(A) and (7). The Commonwealth filed a motion for summary judgment.

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Consumer opinion summary, case decided on August 27, 2012 , LexisNexis #0912-085

Lopez v. First Judicial Dist. (In re Lopez)

Ruling
Court costs of criminal proceeding against debtor were nondischargeable.
Procedural posture

Plaintiff Chapter 7 debtor filed an adversary proceeding against defendants, the First Judicial District of Pennsylvania and a court administrator, seeking a determination that court costs a state court assessed when it convicted the debtor of committing criminal offenses were dischargeable under 11 U.S.C.S. § 523(a)(7). The debtor filed a motion for summary judgment.

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Consumer opinion summary, case decided on July 18, 2012 , LexisNexis #0812-083

Basquin v. Stasson (In re Stasson)

Ruling
Restitution to debtor attorney's client ordered by state discipline board was not payable to or for the benefit of a governmental unit and was dischargeable.
Procedural posture

Plaintiffs, the Michigan Attorney Grievance Commission and a complainant, filed separate adversary proceedings against defendant, an attorney who declared chapter 7 bankruptcy, seeking a determination that an order issued by the Michigan Attorney Discipline Board created debts that were nondischargeable under 11 U.S.C.S. § 523(a)(7). The court consolidated the cases, and the Commission and the attorney filed cross-motions for summary judgment.

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Consumer opinion summary, case decided on March 09, 2012 , LexisNexis #0412-053

Smith v. Sims (In re Sims)

Ruling
Restitution judgment holding debtor liable for son's debt was dischargeable absent evidence of intent of juvenile court.
Procedural posture

Plaintiff filed an adversary complaint to determine the dischargeability of a restitution debt under 11 U.S.C.S. § 523(a)(7).

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Consumer opinion summary, case decided on February 17, 2012 , LexisNexis #0312-047

Department of Environmental Protection v. Thebes (In re Thebes)

Ruling
Department of Environmental Protection penalties for violations of Solid Waste Management Act were not compensation for pecuniary loss and were nondischargeable.
Procedural posture

Plaintiff, the Commonwealth of Pennsylvania Department of Environmental Protection (DEP), sought a declaration under 11 U.S.C.S. § 523(a)(7) that certain debts incurred by the debtor were nondischargeable. The DEP filed a motion for summary judgment.

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Consumer opinion summary, case decided on March 29, 2011 , LexisNexis #0711-017

Love v. Scott (In re Love)

Ruling
Costs assessed in debtor lawyer's disciplinary proceeding were compensation for actual pecuniary losses that were discharged so that nonpayment could not prevent reinstatement of license.
Procedural posture

Plaintiff bankruptcy debtor brought an adversary proceeding against defendant Chairman of the Tennessee Board of Professional Responsibility (TBPR) seeking a determination that the debtor's prior bankruptcy discharge precluded the TBPR from refusing to reinstate the debtor's license as an attorney until the debtor paid prior costs of disciplinary proceedings. The debtor and the Chairman cross-moved for summary judgment.

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Consumer opinion summary, case decided on January 12, 2011 , LexisNexis #0211-055

Ada County Prosecuting Attys Office v. Searcy (In re Searcy)

Ruling
Costs assessed for debtor prisoner's frivolous action against prosecutor was penal in nature and nondischargeable.
Procedural posture

Plaintiff county sought to except from discharge under 11 U.S.C.S. § 523(a)(7) and (a)(17) costs and attorney's fees awarded against defendant debtor, a prisoner.

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Consumer opinion summary, case decided on January 12, 2011 , LexisNexis #0211-056