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§ 523(a)(8)

Morse v. Iowa Student Loan Liquidity Corp. (In re Morse)

Ruling
Student loan obligations were discharged due to undue hardship related to debtor's history of mental illness.
Procedural posture

Plaintiff debtor filed an adversary proceeding against defendant creditor to determine the dischargeability of certain student loan obligations pursuant to 11 U.S.C.S. § 523(a)(8).

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opinion summary, case decided on July 10, 2006 , LexisNexis #0706-133

Lee v. Regions Bank & Student Loan Guar. Found. (In re Lee)

Ruling
Debtor's student loans were deemed dischargeable due to undue hardship since debtor's reasonable expenses greatly exceeded her income.
Procedural posture

Before the court was a complaint to determine the dischargeability of a student loan debt that plaintiff debtor owed to defendant creditor.

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opinion summary, case decided on July 06, 2006 , LexisNexis #0806-129

Nelson v. TG Collections (In re Nelson)

Ruling
Student loan debt was deemed nondischargeable since debtor had sufficient monthly income and stable employment to repay loans.
Procedural posture

Plaintiff debtor filed against defendant creditors an adversary complaint seeking a determination that her student loan debt was dischargeable under 11 U.S.C. § 523(a)(8). The matter was tried to the court.

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opinion summary, case decided on June 22, 2006 , LexisNexis #0706-091

Woody v. United States Dept. of Justice (In re Woody)

Ruling
Undue hardship discharge of student loan debt was not clearly erroneous.
Procedural posture

Creditors, the U.S. Departments of Justice and Education, appealed a final judgment of the Bankruptcy Court for the District of Kansas discharging chapter 7 debtor's Department of Education student loans (the 523 Loan) pursuant to the "undue hardship" provision in 11 U.S.C. § 523(a)(8), debtor's Health Education Assistance Loan (the HEAL loan) pursuant to the "unconscionable"provision in 42 U.S.C. § 292f(g).

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Court :
Judge or Jurisdiction information not available
opinion summary, case decided on June 16, 2006 , LexisNexis #1006-056

Educ. Credit Mgmt. Corp. v. Spence

Ruling
Court reversed bankruptcy court by ruling that debtor had not met three elements for determining debt dischargeability due to undue hardship.
Procedural posture

Before the court was appellant creditor's appeal of an order of the bankruptcy court, which fully discharged appellee debtor's student loan debt owed to the creditor. The creditor argued that the bankruptcy court erred by discharging the debtor's student loan because she would suffer an undue hardship if required to pay her student loan debt.

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opinion summary, case decided on May 12, 2006 , LexisNexis #0706-022

Harkins v. Educ. Credit Mgmt. Corp. (In re Harkins)

Ruling
Court granted debtor partial discharge of student loan debt in reopened case due to undue hardship.
Procedural posture

Plaintiff debtor filed for chapter 7 relief and received a discharge. Four years later, the debtor moved to reopen her case, seeking a discharge of her student loan debt pursuant to 11 U.S.C. § 523(a)(8)(B). Defendant creditor objected. The court had taken the matter under advisement.

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opinion summary, case decided on April 27, 2006 , LexisNexis #0606-057

Dufresne v. N.H. Higher Educ. Assistance Found. (In re Dufresne)

Ruling
Debtor's student loan debt was discharged due to undue hardship.
Procedural posture

By her complaint in an adversary proceeding, debtor sought a discharge of her outstanding student loans on an undue hardship basis under 11 U.S.C. § 523(a)(8). Defendant, the assignee of the loans, opposed their discharge. The matter was before the court for decision following trial.

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opinion summary, case decided on April 25, 2006 , LexisNexis #0506-128

Clark v. United States Dept of Educ. (In re Clark)

Ruling
Student loan debt was deemed nondischargeable since debtor's living expenses were excessive and debtor failed to show good faith efforts to repay.
Procedural posture

Plaintiff bankruptcy debtor brought an adversary proceeding against defendant U.S. Department of Education seeking a discharge of the debtor's student loan debt to the government based on undue hardship under 11 U.S.C. § 523(a)(8). The bankruptcy court conducted a trial.

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opinion summary, case decided on April 11, 2006 , LexisNexis #0406-128

Ardis v. Educ. Credit Mgmt. Corp. (In re Ardis)

Ruling
Finding that debtor was not entitled to hardship discharge of student loan debt was affirmed since debtor did not show a good faith effort to repay.
Procedural posture

Appellant debtor appealed from the Bankruptcy Court's determination that he was not entitled to a hardship discharge of his student loan obligations under 11 U.S.C. § 523(a)(8).

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opinion summary, case decided on April 06, 2006 , LexisNexis #0406-127

Shadwick v. United States Dept of Educ. (In re Shadwick)

Ruling
Debtor was denied a request to discharge student loans since both debtor and debtor's spouse had potential to earn a good income despite their lack of effort.
Procedural posture

Plaintiff debtor filed an adversary proceeding against defendants, creditors, to determine the dischargeability of certain student loan obligations pursuant to 11 U.S.C. § 523(a)(8).

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opinion summary, case decided on March 29, 2006 , LexisNexis #0406-095