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As is often stated, the fresh start in bankruptcy is reserved for the honest but unfortunate debtor.' Thus, while the discharge generally covers prebankruptcy debts,2 it does not extend to debts for culpable misconduct by the debtor.3 The Bankruptcy Code enforces this fundamental tenet in important part through § 523(a)(6), which bars the discharge of debts for "willful and malicious injury."4 Section 523(a)(6) is the most frequently litigated of the several exceptions to the discharge, with thousands of reported trial court and appellate decisions, including a Supreme Court opinion.5 It is a frequent battleground for defining the limits of the scope of the discharge and distinguishing debts that are honestly incurred from those that arise from culpable misconduct by the debtor.