In 1998, Justice O'Connor authorized the Cohen decision. Such decision held that a debt for purposes of 523(a)(2)(A) is not limited to the amount obtained. "Once it is established that specific money or property has been obtained by fraud...'any debt' arising therefrom is excepted from discharge". The Court found that the award of treble damages plus attorney fees under the New Jersey Consumer Fraud Act was nondischargeable.
On July 19, 2013, the Bankruptcy Court in Illinois gave me a quick refresher course of the Cohen decision in In re Speisman (Bankr. N.D. ILL 2013). The decision arose from a motion to dismiss under Rule 9(b).
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