Spring Works, Inc. v. Sarff (In Re Sarff)

How courts have described this case

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

• holding that discovery sanctions are nondischargeable under section 523(a)(6) along with compensatory and punitive damages for breach of duty of loyalty and misappropriation of trade secrets
• finding that a magistrate judge’s $2,000 discovery sanction against party for intentionally redacting discovery records in an attempt to deceive is non-dischargeable under § 523(a)(6)
• recognizing no distinction between compensatory and punitive damages
• reversing bankruptcy court and holding that compensatory damages from breach of duty of loyalty arose from same conduct as other nondischargeable damages constituting willful and malicious injury, thus making them nondischargeable
• finding reliance on advice of counsel is generally not a defense to § 523(a)(6) claims, but courts may recognize it where reliance was reasonable and debtor acted in good faith
• recognizing no distinction between compensatory and punitive damages

Source: CourtListener parenthetical corpus (CC0).