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§ 523(a)(2)(A)

Melnor Inc. v. Corey (In re Corey)

Ruling
Bankruptcy court properly held that default judgment for debtor's failure to appear at trial was nondischargeable.
Procedural posture

Defendant debtor challenged a decision of the Bankruptcy Court for the District of Kansas that found that defendant creditor's claim against him was non-dischargeable pursuant to 11 U.S.C.S. § 523(a)(2)(A). The bankruptcy court granted summary judgment for the creditor because it concluded that a prior judgment that the creditor had obtained in federal district court in Virginia had determined that the debt was procured by fraud.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on October 06, 2008 , LexisNexis #1108-011

In re West

Ruling
Default judgment did not provide basis for finding of nondischargeability based on fraud.
Procedural posture

Plaintiff judgment creditor filed this adversary proceeding to except its judgment debt from discharge on the basis of 11 U.S.C.S. § 523(a)(2)(A), alleging that defendants, debtor husband and his construction company, obtained money from it by false pretenses, false representations, or actual fraud. The creditor moved for summary judgment, asserting that the evidence and the state court judgment established that debtor acted fraudulently.

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Consumer opinion summary, case decided on September 22, 2008 , LexisNexis #1208-014

Hurrell v. Barker (In re Barker)

Ruling
Debtors'alleged nondisclosure of defects in house was not basis for nondischargeable debt where purchaser did not sufficiently investigate.
Procedural posture

Plaintiff purchasers of a house from defendant bankruptcy debtors brought an adversary proceeding against the debtors seeking a determination that the purchasers'claim for the cost of repairs to the house was not dischargeable based on fraud and willful and malicious injury under 11 U.S.C.S. § 523(a)(2)(A), (a)(6). The bankruptcy court conducted a trial.

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Consumer opinion summary, case decided on September 03, 2008 , LexisNexis #1208-095

Emmes Capital LLC v. Fadili (In re Fadili)

Ruling
Debtor's false financial statement, affidavit and failure to respond to written request were insufficient to establish nondischargeability under 523(a)(2)(A).
Procedural posture

Plaintiff judgment creditor filed a motion for summary judgment as to its count against defendant capter 7 debtor, seeking a determination that the prepetition judgment it held against the debtor was excepted from discharge under 11 U.S.C.S. § 523(a)(2)(A).

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Consumer opinion summary, case decided on September 03, 2008 , LexisNexis #1008-030

Machanic v. Clark (In re Clark)

Ruling
Debt owed to purchaser of debtor's former residence was dischargeable absent proof of intent to deceive or purcasher's reliance on representations.
Procedural posture

After defendant debtor filed for chapter 7 bankruptcy protection, plaintiff purchaser initiated an adversary proceeding, seeking a determination that the debtor was required to reimburse her for the money she had spent and would spend to correct alleged undisclosed problems with a house she purchased from him. The purchaser also alleged that the damages were nondischargeable under 11 U.S.C.S. § 523(a)(2)(A).

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Consumer opinion summary, case decided on September 03, 2008 , LexisNexis #0908-079

Fee v. Eccles (In re Eccles)

Ruling
Debt was nondischargeable due to debtors'false representations regarding use of creditor's funds.
Procedural posture

Plaintiff trustee sued defendant creditors, alleging slander of title that resulted from the lis pendens recorded by the creditors in connection with a pre-petition state court lawsuit. The creditors brought an adversary proceeding against defendant debtors, alleging that a loan was nondischargeable under 11 U.S.C.S. § 523(a)(2)(A) and requesting, inter alia, an equitable lien on the debtors'property. A trial was held on the consolidated cases.

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Consumer opinion summary, case decided on July 23, 2008 , LexisNexis #1008-078

Sprouse v. Rebel Log Homes (In re Sprouse)

Ruling
Creditors entitled to default nondischargeability judgment where debtor refused to produce requested documents.
Procedural posture

Plaintiffs, former customers of defendant debtor, a contractor, filed a motion for Fed. R. Civ. P. 37 sanctions, for default judgment per Fed. R. Civ. P. 55, and for legal fees arising from debtor's failure to provide discovery on their claim, filed in his bankruptcy, that a default judgment including punitive damages that was won by plaintiffs in a state court action against debtor was nondischargeable pursuant to 11 U.S.C.S. § 523(a)(2)(A).

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Consumer opinion summary, case decided on July 15, 2008 , LexisNexis #0808-093

FIA Card Servs. v. Flowers (In re Flowers)

Ruling
Credit card cash advance properly held to be dischargeable.
Procedural posture

In an appeal to the district court, appellant creditor challenged two decisions of the United States Bankruptcy Court for the Middle District of Alabama in an adversary proceeding: (1) its summary-judgment holding that appellee debtor's credit-card cash-advance debt to the creditor was dischargeable and (2) its award of attorney's fees to debtor from creditor.

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Consumer opinion summary, case decided on July 11, 2008 , LexisNexis #0808-044

Lerario v. Nardone (In re Nardone)

Ruling
Debtor collaterally estopped from challenging nondischargeability of consent judgment.
Procedural posture

Plaintiff judgment creditors brought an adversary proceeding against defendant chapter 7 debtor, seeking to hold the debt arising from a consent judgment nondischargeable pursuant to 11 U.S.C.S. § 523(a)(2)(A).

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Consumer opinion summary, case decided on July 07, 2008 , LexisNexis #0808-062

Strikland v. Carter (In re Carter)

Ruling
State court judgment that did not set forth findings of fraud was dischargeable.
Procedural posture

Plaintiffs, creditors, filed an adversary proceeding against defendants, debtors, seeking a determination that their debt was nondischargeable pursuant to 11 U.S.C.S. § 523(a)(2)(A). The creditors held a judgment debt and contended that the judgment was entitled to preclusive effect. The creditors moved for entry of a final judgment of nondischargeability.

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Consumer opinion summary, case decided on July 07, 2008 , LexisNexis #1208-079