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§ 523(a)(2)(A)

Kahle, In re--Toscano v. Kahle

Ruling
Summary judgment in nondischargeability proceeding denied as the court could not determine the scope of a potentially applicable release contained in settlement agreement from the language of the agreement alone. (Bankr. E.D. Wis.)
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 August 22, 2025 , LexisNexis #1025-080

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

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

Bortz, In re--Lavender v. Bortz

Ruling
Debt was excepted from discharge as debtor obtained funds through false representations and actual fraud in failed construction project. (Bankr. S.D. Tex.)
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 May 16, 2025 , LexisNexis #0725-062

Mascareno, In re

Ruling
Court found insufficient evidence to support a finding that debtor knew any representations he made were false or that he made them with the intent to deceive. (Bankr. S.D. Tex.)
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 March 21, 2025 , LexisNexis #0525-084

Taylor, In re

Ruling
Debt was nondischargeable as debtor knowingly made false promises to the customer with the intent to deceive him into paying the deposits and then performing little to no work. (Bankr. D. Alaska)
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 March 12, 2025 , LexisNexis #0525-033

George, In re

Ruling
Debtor’s failures to report employment and income constituted false representations and omissions intended to induce the SSA to continue paying benefits. (Bankr. E.D. Wis.)
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 March 06, 2025 , LexisNexis #0525-011

Gividen, In re--Robb v. Gividen

Ruling
Creditors failed to sufficiently allege facts to state plausible claims for nondischargeabilty under the applicable pleading standards. (Bankr. N.D. Ga.)
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 January 22, 2025 , LexisNexis #0325-087

Kennedy, In re--Berrian v. Kennedy

Ruling
Debt was dischargeable as the debt was owed by construction company not by its debtor owner personally, and the evidence did not support piercing the corporate veil or applying participation theory. (Bankr. E.D. Pa.)
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 January 22, 2025 , LexisNexis #0325-060

Fletcher, In re

Ruling
Consent judgment explicitly made no factual findings other than the amount of the debt, so there were no issues actually litigated to which collateral estoppel could apply. (Bankr. S.D. Fla.)
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 January 21, 2025 , LexisNexis #0325-059