When “Solely” Means Solely: Why the Pearson Decision Matters for Private Student Loan Dischargeability

At the center of a recent decision argued by Attorney Doling is a deceptively simple word: “solely.” Doling shares how the Ninth Circuit BAP takes that word very seriously.

Unlock This Article

To get started, please let us know which of these best fits your current position:

Please sign in to continue reading this content.

JD headshot
Attorney for Appellant, Vice President, NACBA (Palm Desert, CA)

Jenny L. Doling is the founding shareholder of J. DOLING LAW, PC, a bankruptcy, tax and insolvency law firm representing clients throughout California. She is a California State Bar Certified Bankruptcy Specialist. Ms. Doling represents creditors, trustees, and consumer and business debtors in chapter 7, 11, 12, and 13 bankruptcy cases and appeals. She earned her Taxation LL.M. from the University of San Diego School of Law. Ms. Doling was recently appointed by U.S. Supreme Court Chief Justice John G. Roberts, Jr. to serve a second 3-year term on the National Judicial Conference Bankruptcy Rules Committee.

Ms. Doling is an active member of the bankruptcy bar. She is the 2025-2028 Vice-President and member of the Board of Directors for the National Association of Consumer Bankruptcy Attorneys (NACBA). She is the immediate Past-President of the San Diego Bankruptcy Forum, and a Past-President of the Inland Empire Bankruptcy Forum. Further, Ms. Doling is a frequent speaker on bankruptcy and tax controversy topics for NACBA, the National Conference of Bankruptcy Judges (NCBJ), National Association of Chapter Thirteen Trustees (NACTT), the American Bankruptcy Institute (ABI), and the California Bankruptcy Forum (CBF). In addition, Ms. Doling has been the Professor of Bankruptcy law at the California Desert Trial Academy (CDTA) since 2015. She also serves on the Central District of California Bar Advisory Committee. Ms. Doling is admitted to practice in all state and federal courts in California and Nevada. In addition, she is admitted to the U.S. Tax Court where she handles tax matters across the United States. She is also admitted to practice before the United States Ninth and Tenth Circuit Courts of Appeals. She received her Juris Doctorate from California Western School of Law in San Diego. Ms. Doling was on the Dean’s Honor List and was also the recipient of the Dean’s Merit Scholarship. She received an Academic Achievement Award in Bankruptcy and was also honored with an Award for Excellence from the American Bankruptcy Law Journal. Ms. Doling received her Bachelor of Arts degree in Criminal Justice. She was a member of the Desert Defenders Conflict Panel for Riverside County representing indigent clients in Misdemeanor cases under the Conflict Panel for nearly 10 years.

Related Articles

Copy of Hildebrand-2016
March 2, 2025
Debtor is not entitled to receive title to automobile, treated under the Chapter 13 plan, even though the claim is fully paid in accordance with the plan.
Members
January 19, 2020
By Henry E. Hildebrand, III, Chapter 13 Standing Trustee for the Middle District of Tennessee (Nashville) Chapter 7 debtor may successfully discharge student loan obligations by satisfying the basic holding of Brunner v. N.Y. State Higher Education Servs. Corp. rather than satisfying the judicial gloss added by subsequent decisions. Rosenberg v. N.Y. State Higher Education Servs. Corp., 2020 WL 130302...
Members
May 2, 2021
By Cathy Moran, Esq., (Redwood City, CA) I don't know just what makes Parker such a treat for me, but it delivers multiple thrills to my bankruptcy lawyer heart. It's a stay violation case with a BIG sanctions award. It's a clearly, simply written opinion that lays out the circuit law on multiple issues. It hits hard at HOA hubris....
Members
September 22, 2019
By Jan Hamilton, Chapter 13 Standing Trustee (Topeka, KS) I. The Plan1 A. Notions to Consider before the Plan is Filed… Time for Filing of the Plan. No later than 90 days after the filing of the case, the debtor is required to file a plan, unless the court extends the time if the “need is attributable to circumstances for...
Members
February 24, 2019
On June 26, 2017, Bradford W. Caraway was appointed as the Chapter 13 Standing Trustee for the Northern District of Alabama, Southern Division. He replaced D. Sims Crawford who had been appointed as a United States Bankruptcy Judge for the Northern District of Alabama. Trustee Caraway maintains his office in Birmingham. At the time of his appointment as Standing Trustee,...
Members
bledsoe150
August 27, 2023
The Eighth Circuit recently released its Topp opinion. At issue was the appropriate starting point for determining the discount rate to be used when paying secured claims under a chapter 12 plan. The debtor, who had gained confirmation of his plan before the bankruptcy court, proposed paying claims to Farm Credit Services over 20 years at a rate based on the...
Members
January 19, 2020
By David Cox,1 Cox Law Group, PLLC (Lynchburg, VA) Click here for Part 1 of 3 Click here for Part 2 of 3 C. Challenges unique to older debtors. Mobility/hearing attendance requirements. Attendance at 341 hearing. Section 343 Examination of the debtor clearly . . . It looks like you are not signed in or registered! This content is only...
Members
joseph 12-2024
July 28, 2024
Could it be that chapter 13 got it right? How does the recent United States Supreme Court holding in Harrington v. Purdue Pharma impact chapter 13 cases?
Members
July 28, 2019
Tiffany M. Cornejo was appointed as the Chapter 13 Standing Trustee for the District of New Mexico on December 1, 2017. She took the reins from retiring Kelley Skehen. Ms. Cornejo received her Bachelor of Science in Journalism (B.S.J.) degree at the University of Kansas in Lawrence in 2002 and remained there to obtain her Juris Doctor in 2005. She...
January 19, 2020
By Craig Shopneck, Chapter 13 Standing Trustee for the Northern District of Ohio Retired It was many months ago when Mike Joseph asked, if, as a retired trustee, would I be interested in writing an article for the NACTT Academy. This may seem like a rather straightforward task but before putting pen to paper I needed time to reflect not...
Members

Looking to Become a Member?

ConsiderChapter13.org offers a forum to advance continuing education of consumer bankruptcy via access to insightful articles, informative webinars, and the latest industry news. Join now to benefit from expert resources and stay informed.

Webinars

These informative sessions are led by industry experts and cover a range of consumer bankruptcy topics.

Member Articles

Written by industry experts, these articles provide in-depth analysis and practical guidance on consumer bankruptcy topics.

Industry News

The Academy is the go-to source for the latest news and analysis in the Chapter 13 bankruptcy industry.

To get started, please let us know which of these best fits your current position: