Supreme Court Holds That Fraud Exception to Debt Discharge can Include Fraud by Someone Other Than the Debtor
We have previously blogged about Bartenwerfer v. Buckley, No. 21-908, a Supreme Court case concerning the scope of the fraud exception to the dischargeability of debts in bankruptcy. Section 523 of the Bankruptcy Code exempts from discharge “any debt . . . for money, property, services, or an extension, renewal, or refinancing of credit, to the extent obtained by . . . false pretenses, a false representation, or actual fraud. . . .” 11 U.S.C. § 523(a)(2)(A). Bartenwerfer considers whether the fraud required by this section need be the debtor’s fraud or fraud known to the debtor. On February 22, the Supreme Court answered no.