In Re Bandilli’s Empirical Analysis

Citation profile

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 1 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““In order to qualify for a hardship discharge, the Debtors must persuade the Court that they have complied with each subsection of section 1328(b).” In re White, 126 B.R. 542, 545 (Bankr.N.D.Ill.1991).... Regarding subsection (1) of 1328(b), most courts have limited its application to compelling circumstances. See id. (and cases cited therein). A Chapter 13 guru has written that a hardship discharge is “reserved for the truly worst of the awfuls.... ” K. Lundin, Chapter 13 Bankruptcy, § 9.18 at 9-26 (1990). Some courts take a more relaxed approach and allow a hardship discharge “due to economic circumstances that did not exist nor were foreseeable at the time of confirmation of the plan, where those circumstances are beyond the debtor’s control, and where the debtor has made every effort to overcome those circumstances but is unable to complete his plan payments.” In re Edwards, 207 B.R. 728 (Bankr.N.D.Fla.1997).”

   1 later decision quote this exact passage
   e.g. In Re Roberts