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Ford v. Student Loan Guarantee Found. of Arkansas
269 B.R. 673 (8th Cir. 2001) ; Clearinghouse Number: 54308
Description
Bankruptcy Appellate Panel for Eighth Circuit Affirms Discharge of Student Loan Debt
Abstract
The Bankruptcy Appellate Panel for the Eighth Circuit affirmed the
judgment discharging debtor-appellee’s student loan debt.
Debtor-appellee, a 62-year-old woman filing a Chapter 7 petition,
filed an adversary action in bankruptcy court to have her $73,000
in student loan debts discharged. Finding that failure to discharge
the debt would impose an undue hardship on debtor-appellee, the
bankruptcy court declared the debt dischargeable. Reviewing for
clear error, the bankruptcy appellate panel applied the Eighth
Circuit’s “totality of circumstances” test to
determine undue hardship. Citing evidence in the record of
debtor-appellee’s modest expenses, limited income, and
deteriorating physical condition, the appellate panel affirmed the
bankruptcy court’s finding of undue hardship.
