From the Editor – Discharge Injunction

By The Honorable William Houston Brown (Retired)

Section 524(i) applies only to long-term debts not discharged through plan. Whether § 524(i) applied to short-term secured debts that are paid in full and discharged through a Chapter 13 plan was a matter of first impression, with the Court finding no other court had yet decided precise question. Factors used in Supreme Court’s interpretations of BAPCPA’s amendments included: statutory language, context of the specific amendment, whether other Code provisions are affected, and Congressional purpose in the amendment. The Court concluded that “a reading . . .

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