Washington

Cohen v. de la Cruz in Washington Law

How Cohen v. de la Cruz applies in Washington: state-specific rules, key cases, and bar exam notes for Bankruptcy.

State Approach

Washington courts follow the federal precedent established in Cohen v. de la Cruz when determining the dischargeability of debts arising from fraud or malice. State laws reinforce the importance of honoring bankruptcy protections while ensuring that debtors cannot escape liability for wrongful acts.

State Rule
In Washington, debts incurred as a result of actual fraud or willful and malicious injury are generally not dischargeable under RCW 19.86 and relevant sections of the Bankruptcy Code, consistent with Cohen v. de la Cruz.
Significant State Cases

In re Young

The court held that debts stemming from intentional misrepresentation were not dischargeable in bankruptcy, aligning with the Cohen precedent.

In re McCarthy

The ruling articulated that debts arising from willful and malicious injuries to another party's property are non-dischargeable, consistent with Cohen.

In re Morris

The court emphasized that fraudulent debts do not benefit from bankruptcy protections, reinforcing the principles observed in Cohen.

Comparison to Federal Law

Washington courts adhere to the federal standard regarding non-dischargeable debts for fraud and malicious acts established in Cohen v. de la Cruz. While federal bankruptcy law provides the overarching framework, Washington effectively enforces these principles through its statutes, maintaining consistency with nationwide practices.

Bar Exam Note

Cohen v. de la Cruz principles regarding dischargeability are often tested in the Washington bar exam, particularly in the context of consumer bankruptcy and fraud.

Practice Pointers
  • Familiarize yourself with the differences between dischargeable and non-dischargeable debts under both Washington law and federal bankruptcy law.
  • Pay close attention to definitions of fraud and malice in the context of bankruptcy to apply Cohen's principles correctly.
  • Review recent Washington bankruptcy cases to understand how courts interpret fraud claims and non-dischargeable debts.

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