In Re: Michael J. Oyler, Debtor. Michael J. Oyler v. Educational Credit Management Corporation

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that because Oyler had failed the second prong of the Brunner test, he had failed to demonstrate undue hardship under that test
• noting that the “additional circumstances” under the Brunner test must be “beyond the debt- or’s control, not borne of free choice”
• holding that additional circumstances includes “a large number of dependents”
• noting that the “additional circumstances” under the Brunner test must be “beyond the debtor’s control, not borne of free choice”
• finding that debtors must make reasonable efforts to maximize income to meet their loan obligations before claiming undue hardship
• adopting the Brunner standard because it is a “simpler rubric” and “easily accommodates factors [the court] looks to in evaluating undue hardship”

Source: CourtListener parenthetical corpus (CC0).