Sauer Incorporated v. Lawson
Court of Appeals for the First Circuit
1Opinion of the Court
LYNCH, Circuit Judge.
Sauer Incorporated (“Sauer”) filed an adversary proceeding objecting to the discharge of a debt owed by Carrie Lawson (“Ms. Lawson”) that she allegedly obtained as part of a fraudulent scheme to prevent Sauer from collecting a previous judgment from her father, James Lawson. See 11 U.S.C. §§ 523(a)(2)(A), 523(a)(6). The bankruptcy court dismissed for failure to state a claim on the ground that a debt for value “obtained by ... actual fraud” under § 523(a)(2)(A) is limited to debts for value obtained through fraudulent misrepresentations. The court felt First Circuit…
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