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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision
Mar 03, 1998

Lebovits v. Chase Manhattan Bank (In Re Lebovits)

Daniel Lebovits, a Chapter 7 debtor, filed an adversary proceeding to discharge his student loan debt, arguing it imposed an "undue hardship." The U.S. Bankruptcy Court for the Eastern District of New York, Judge Dorothy Eisenberg, found that repayment of the $49,040.12 debt would indeed cause undue hardship for Lebovits and his seven dependents. The court applied the three-prong Brunner test, determining that Lebovits could not maintain a minimal standard of living, his financial difficulties would persist, and he had made good faith efforts to repay. Consequently, the court granted the discharge of the student loans.

Student Loan DischargeUndue HardshipBankruptcy Chapter 7Brunner TestDebtor's DependentsFinancial HardshipMinimal Standard of LivingGood Faith RepaymentReligious FreedomFamily Expenses
References
19
Case No. MISSING
Regular Panel Decision

Goldman v. Bank of New York (In Re Goldman)

Cecilia R. Goldman, a Chapter 7 debtor, sought to discharge her student loan obligation from The Bank of New York, guaranteed by NYSHESC, claiming undue hardship due to health issues and related medical expenses. NYSHESC objected, stating that the five-year repayment period had not elapsed and that repayment would not cause undue hardship. The court determined that despite her medical condition, Goldman was employed with a $17,000 annual salary, was single, had no dependents, and had discharged over $13,000 in other debts. The court concluded that Goldman failed to prove the 'hopelessness or exceptional circumstances' necessary for an undue hardship finding under 11 U.S.C. § 523(a)(8)(B), and consequently, her complaint was dismissed.

Student LoanBankruptcyUndue HardshipChapter 7DischargeabilityMedical ConditionFinancial HardshipGuaranteed LoanFederal Bankruptcy CodeDebtor-Creditor Law
References
6
Case No. MISSING
Regular Panel Decision

Stern v. Education Resources Institute Inc. (In Re Stern)

James E. Stern, a 35-year-old attorney, sought to discharge his student loans totaling over $100,000 under Chapter 7 bankruptcy, arguing "undue hardship" under Code § 523(a)(8). Stern, who recently closed his law practice due to rising malpractice insurance costs and moved to France with his wife, contended he could not maintain a minimal standard of living if forced to repay the loans. Defendants, TERI and ECMC (assignee of ASA), argued Stern failed the three-prong Brunner test for undue hardship. The court found that while Stern met the first prong (current inability to pay), he failed the second, as his financial hardship was not deemed long-term or beyond his reasonable control, particularly given his education, lack of disability, and his choice to move abroad rather than seek employment in the U.S. Consequently, the court denied both a full and partial discharge of his student loan obligations.

student loansundue hardshipbankruptcy dischargeChapter 7Brunner testfinancial difficultylegal careeremployment prospectsinternational relocationeducational debt
References
10
Case No. MISSING
Regular Panel Decision

Thoms v. Educational Credit Management Corp. (In Re Thoms)

Kashima Thoms, a Chapter 7 debtor, initiated an adversary proceeding seeking the discharge of her substantial student loan obligations totaling $90,948.58, citing "undue hardship" under 11 U.S.C. § 523(a)(8). Educational Credit Management Corp. (ECMC) became the primary defendant, administering all of Thoms's student loans. The U.S. Bankruptcy Court applied the Second Circuit's stringent three-part Brunner test, which requires demonstrating an inability to maintain a minimal living standard, persistence of this hardship, and good faith repayment efforts. The Court found that Thoms, earning $48,000 annually, had sufficient disposable income, and her financial prospects were likely to improve, particularly with potential changes in childcare expenses and family living arrangements. Crucially, Thoms had made only minimal payments years prior and failed to utilize available loan restructuring options, thereby failing to prove good faith. Consequently, the Court ruled that Thoms did not establish undue hardship, denying the discharge of her student loan debts.

Bankruptcy LawStudent Loan DischargeUndue Hardship DoctrineBrunner TestChapter 7 BankruptcyAdversary ProceedingFinancial DistressRepayment EffortsFederal Student LoansDebtor-Creditor Law
References
4
Case No. MISSING
Regular Panel Decision
Jan 26, 1982

Hodge v. D'Elia

This case involves a proceeding under CPLR article 78 to review a determination by the State Commissioner of Social Services. The determination affirmed a local agency's decision to reduce the petitioner's public assistance grant. This reduction was for the recoupment of income tax refunds and workers' compensation benefits received by the petitioner. Although the court agreed that the petitioner willfully withheld information, it found that the respondents failed to evaluate if the recoupment rate would cause undue hardship. Consequently, the court annulled the determination and remitted the matter for further proceedings to assess undue hardship.

Public AssistanceRecoupmentIncome Tax RefundsWorkers' Compensation BenefitsUndue HardshipCPLR Article 78Administrative ReviewFair HearingAnnulmentRemittal
References
1
Case No. MISSING
Regular Panel Decision

Schweizer Aircraft Corp. v. State Division of Human Rights

This appeal concerns the interpretation of Executive Law § 296 (10)(c), which prohibits employment discrimination based on sabbath observance unless it causes undue economic hardship to the employer. James Amrhein, a Seventh Day Adventist, was denied a machine operator position at Schweizer Aircraft Corporation because he could not work Friday evenings. The employer claimed accommodation was unworkable without attempting to contact other employees or the union. The Court of Appeals reversed the Appellate Division's decision, reinstating the Human Rights Appeal Board's determination that the employer failed to meet its burden of proving undue economic hardship, as it did not make a good faith effort to accommodate Amrhein's religious practice before denying employment.

DiscriminationSabbath ObservanceReligious AccommodationExecutive LawUndue Economic HardshipCollective Bargaining AgreementBurden of ProofShift ExchangeGood Faith EffortEmployment Law
References
0
Case No. MISSING
Regular Panel Decision

Crider v. UNIVERSITY OF TENNESSEE KNOXVILLE

Kimberly Crider, a Seventh Day Adventist, sued the University of Tennessee under Title VII, alleging failure to accommodate her religious beliefs. Crider, a Coordinator in the Programs Abroad Office, was unable to work from sundown Friday to sundown Saturday due to her observance of the Sabbath, which conflicted with her job requirement to monitor an emergency cell phone and participate in weekend events. The University attempted to find accommodations but concluded that doing so would impose an undue hardship on the business or other employees. The court found that Crider established a prima facie case of religious discrimination, but the University successfully demonstrated that no reasonable accommodation could be made without undue hardship. Therefore, the court granted the University's motion for summary judgment and dismissed the action.

Religious DiscriminationTitle VIIFailure to AccommodateSeventh Day AdventistSabbath ObservanceSummary JudgmentUndue HardshipEmergency ProtocolCoordinator PositionUniversity Employment
References
21
Case No. MISSING
Regular Panel Decision

Dyer v. University of Tennessee (In Re Dyer)

The debtor, a 34-year-old single individual residing with his mother and sister, sought to discharge two student loans totaling $14,307.63 due to undue hardship caused by agoraphobia, an anxiety disorder. This condition severely impairs his ability to obtain and retain suitable full-time employment, leaving him reliant on his family for basic necessities and medication. Medical professionals, including Dr. Edwin S. Rogers and Dr. Lane D. Cook, testified to his chronic condition and poor prognosis for full-time work. The court, presided over by Bankruptcy Judge Clive W. Bare, determined that requiring repayment would impose an undue hardship, considering the debtor's medical problems and limited earning potential. Consequently, the court granted the discharge of the student loans.

AgoraphobiaAnxiety DisorderStudent Loan DischargeUndue HardshipBankruptcy CodeMental IllnessInability to workFinancial DistressMedical TestimonyBankruptcy Law
References
5
Case No. MISSING
Regular Panel Decision

Dunn v. Kaladjian

Plaintiffs, a group of New York City residents, brought a class action challenging the City and State's administration of the Home Energy Assistance Program (E-HEAP). This Memorandum and Order addresses the plaintiffs' Federal Rule of Civil Procedure 60(b)(6) motion for relief from a March 27, 2007 summary judgment order, arguing that defendants continued to fail in providing E-HEAP notice and properly labeling eligible households. District Judge Joseph F. Bianco denied the motion, finding that the plaintiffs did not present "highly convincing" evidence to warrant relief. The Court further concluded that plaintiffs delayed unreasonably in filing and that granting relief would cause undue hardship to the defendants. Ultimately, the plaintiffs failed to demonstrate extraordinary circumstances or undue hardship to themselves, thus warranting the denial of their motion.

Class ActionRule 60(b)(6) MotionSummary JudgmentHome Energy Assistance ProgramE-HEAPPublic AssistanceDue ProcessNotice RequirementsMislabelingRepayable Loans
References
23
Case No. MISSING
Regular Panel Decision
Mar 11, 1992

Gordon v. MCI Telecommunications Corp.

Shari Shapiro Gordon, an Orthodox Jewish woman, filed a religious discrimination lawsuit against MCI Telecommunications Corp. under Title VII and New York Human Rights Law. Gordon alleged that MCI refused to hire her for a Staff Assistant position due to her need to leave work early on Fridays during the fall and winter for Sabbath observance. MCI moved for summary judgment, contending that Gordon failed to establish a prima facie case and that accommodating her religious practices would impose an undue hardship. The court denied MCI's motion, finding that Gordon had presented sufficient evidence for a reasonable trier of fact to conclude a prima facie case of discrimination. Furthermore, MCI's claims of undue hardship were deemed speculative, lacking concrete evidence regarding actual operational disruptions or financial burdens. The case will proceed to trial.

Religious DiscriminationEmployment LawTitle VIINew York Human Rights LawSabbath ObservanceUndue HardshipReasonable AccommodationSummary JudgmentPrima Facie CaseFederal District Court
References
17
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