Courts Granted Discharge When Federal Law Said No

Verified 7-district sample: 264 cases where Section 1328(f) bar applied

43.2% discharged
anyway
114 discharged in sample Granted despite statutory bar
150 dismissed Case failed (bar not tested)
What this means: In a verified multi-district sample of 114 cases, debtors filed a new Chapter 13 before the statutory waiting period expired. Federal law (11 U.S.C. §1328(f)) prohibits discharge in these cases. No court, trustee, or automated system flagged the violation.
Source: 1328f.org · Verified against PACER dockets, filing-date-to-filing-date methodology

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