Courts Granted Discharge When Federal Law Said No
Verified 7-district sample: 264 cases where Section 1328(f) bar applied
114 discharged
Granted despite statutory bar
150 dismissed
Case failed (bar not tested)
What this means: In 114 verified 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