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8th circuit

Williams v. Adams

Ruling
Dram shop judgment was not automatically excepted from discharge due to differing state and code standards for willful wanton and malicious conduct.
Procedural posture

Plaintiffs, creditors, filed an adversary proceeding against defendant debtor seeking a determination that its debt was nondischargeable pursuant to 11 U.S.C. § 523(a)(6). The creditors had obtained a state court judgment against, inter alia, the debtor. The judgment imposed liability on the debtor, who had owned a restaurant and bar, under Missouri's dram shop law. The creditors moved for summary judgment based on collateral estoppel.

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opinion summary, case decided on August 17, 2006 , LexisNexis #0906-125

In re Skaggs

Ruling
Case dismissed for substantial abuse due to debtor's excessive monthly income.
Procedural posture

The United States Trustee filed a motion to dismiss the debtors' case pursuant to 11 U.S.C. § 707(b)(2) on the grounds that the filing constituted a substantial abuse of the provisions of chapter 7.

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opinion summary, case decided on August 16, 2006 , LexisNexis #1106-015

Lange v. Schropp (In re Brook Valley IV J.V.)

Ruling
Principals of debtor who formed new entities which purchased debtor's properties at foreclosure sale without disclosure to court ordered to turn over excess proceeds and profits.
Procedural posture

Appellee bankruptcy trustee brought an adversary proceeding against appellants, the principals of bankruptcy debtor partnerships, alleging that the principals breached fiduciary duties by secretly purchasing real properties of the debtor for their own benefit. The principals appealed the judgment in favor of the trustee entered in the Bankruptcy Court for the District of Nebraska.

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Court :
Judge or Jurisdiction information not available
opinion summary, case decided on August 15, 2006 , LexisNexis #0906-002

Steil v. Steil

Ruling
Willful breach of lease did not result in nondischargeable debt absent proof of maliciousness.
Procedural posture

Plaintiff filed a complaint seeking to except debt from discharge under 11 U.S.C. § 523(a)(6) based on defendant debtors'conversion of his collateral, inventory in a convenience store leased by the debtors. The debtors denied the disposition of the collateral was willful or malicious.

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opinion summary, case decided on August 14, 2006 , LexisNexis #1106-026

T.K. v. Love (In re Love)

Ruling
Damages owed to minor molested by debtor who was working as Santa Claus were excepted from discharge.
Procedural posture

Plaintiff, an individual acting on behalf of a minor child, filed an adversary proceeding against defendant debtor, seeking a determination of nondischargeability under 11 U.S.C. § 523(a)(6) of any damages that the minor may have obtained for the willful and malicious injury caused by the debtor when he sexually molested the minor. The individual moved for summary judgment.

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opinion summary, case decided on August 10, 2006 , LexisNexis #0906-023

Bentley v. Nissan Motor Acceptance Corp. (In re Bentley)

Ruling
Creditor's knowing repossession of debtor's vehicle was a willfull violation of stay.
Procedural posture

Plaintiff bankruptcy debtor brought an adversary proceeding against defendant creditor for violating the automatic stay by postpetition repossession of the debtor's vehicle. In the debtor's main case, the debtor also objected to the creditor's amended proof of claim, and the creditor moved for relief from the stay. The bankruptcy court conducted a trial addressing all of these matters.

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opinion summary, case decided on August 10, 2006 , LexisNexis #0906-017

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

Ruling
Panel affirmed judgment discharging student loan debt due to undue hardship.
Procedural posture

Appellant, the U.S. Department of Education ("DOE"), sought review of a judgment from the Bankruptcy Court for the Northern District of Iowa, which determined that debtor's obligation to the DOE on her student loans was discharged under 11 U.S.C. § 523(a)(8).

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Court :
Judge or Jurisdiction information not available
opinion summary, case decided on August 10, 2006 , LexisNexis #0806-130

In re Espey

Ruling
Refunds received under IRS Earned Income Credit and state tax law were not "local" public assistance benefits and were not exempt.
Procedural posture

A chapter 7 trustee objected to a debtor's claimed exemption under 11 U.S.C. § 522(d)(10)(A) of state and federal tax refunds under the Internal Revenue Service Earned Income Credit ("EIC") and Minnesota Department of Revenue Working Family Credit ("WFC") public assistance programs.

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opinion summary, case decided on August 08, 2006 , LexisNexis #0906-020

Daniel v. Boyd (Boyd)

Ruling
Debtor was denied discharge due to debtor's concealment of property interests and inaccurate income data.
Procedural posture

Plaintiffs, creditors, filed a complaint to determine dischargeability and an objection to discharge. The issues were whether: (1) the debtor's discharge should be denied under 11 U.S.C. § 727(a)(2)(A); (2) the debtor's discharge should be denied under 11 U.S.C. § 727(a)(4)(A); and (3) the debt to the creditors was nondischargeable pursuant to 11 U.S.C. § 532 (a)(2)(A).

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opinion summary, case decided on August 08, 2006 , LexisNexis #0806-136

In re Batzkiel

Ruling
Debtor's petition did not create presumption of abuse where monthly income was below threshold.
Procedural posture

After the debtors filed a chapter 7 bankruptcy petition, the trustee moved to dismiss pursuant to 11 U.S.C. § 707(b)(1).

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opinion summary, case decided on August 07, 2006 , LexisNexis #1106-014