523

Eleventh Circuit Reads Husky Narrowly, Perhaps Too Narrowly

Reading Husky narrowly, the Eleventh Circuit requires that fraud occur before a debt arises to make the debt nondischargeable under Section 523(a)(2)(A).
Court: 

Repaying Salary After Arrest Isn’t Compensation for Loss and Isn’t Dischargeable

An obligation can be penal in nature, and thus nondischargeable, even though it’s measured by pecuniary loss.

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