By The Honorable William Houston Brown (Retired)
Portion of divorce award was priority domestic support claim and portion dischargeable unsecured claim. Applying Third Circuit’s factors from In re Gianakas, 917 F.2d 759 (3d Cir. 1990), and considering special master’s intent in divorce proceedings, one-third of former spouse’s claim was priority domestic support but two- thirds was reclassified as general unsecured that would be subject to discharge. In re Laspina, 611 B.R. 219 (Bankr. E.D. Penn. 2020).
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