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In Re: John Scott Hamilton in Re: Charlotte Belle Hamilton, Formerly Known as Charlotte B. Allaway, Formerly Known as Charlotte B. Allaway-Hamilton, Debtors. Hartwood Aviation, Inc. Hartwood Paracenter, Inc. Harry C. Schoelpple and Robert T. Dorminey v. John Scott Hamilton, Also Known as J. Scott Hamilton

Citations: 46 F.3d 1151; 1994 U.S. App. LEXIS 40453; 1994 WL 724618Docket: 94-1173

Court: Court of Appeals for the Tenth Circuit; December 19, 1994; Federal Appellate Court

Narrative Opinion Summary

In this appellate case, the court examined the dischargeability of a debt under the bankruptcy code, specifically 11 U.S.C. § 523(a)(6), following a Virginia jury's finding that the debtor's conduct was 'willful and wanton.' The primary legal issue was whether this finding was equivalent to the 'willful and malicious' standard necessary for determining non-dischargeability under the bankruptcy code. The Tenth Circuit reviewed the bankruptcy court's decision, which relied on prior Tenth Circuit rulings that equated 'willful and wanton' conduct with 'willful and malicious' conduct. Consequently, the court affirmed that the debtor, John Scott Hamilton, could not relitigate the matter of dischargeability. The district court's affirmation of the bankruptcy court's ruling was upheld, with the appellate court finding no errors in the decision. It was noted that the appellate decision does not serve as binding precedent, except under particular legal doctrines, and is subject to citation conditions as per a General Order from November 29, 1993. The outcome solidified the non-dischargeability of Hamilton's debt, confirming the alignment of jury findings with bankruptcy standards.

Legal Issues Addressed

Dischargeability of Debt under Bankruptcy Code 11 U.S.C. § 523(a)(6)

Application: The court determined that the jury's finding of 'willful and wanton' conduct was equivalent to the 'willful and malicious' standard required for non-dischargeability of debt under the bankruptcy code.

Reasoning: The key issue on appeal was whether this jury finding was equivalent to the 'willful and malicious' conduct standard required for non-dischargeability under the bankruptcy code.

Issue Preclusion in Bankruptcy Proceedings

Application: The appellate court upheld the bankruptcy court's determination that the issue of dischargeability could not be relitigated due to the prior determination of 'willful and wanton' conduct by a jury, which was found to be equivalent to 'willful and malicious' conduct.

Reasoning: Consequently, the court concluded that Hamilton was precluded from relitigating the dischargeability of his debt.

Precedential Effect of Appellate Decisions

Application: The decision of the appellate court is not considered binding precedent, except under specific legal doctrines, and may only be cited in accordance with conditions outlined in a General Order.

Reasoning: The ruling is not binding precedent except under specific legal doctrines and may be cited under certain conditions outlined in a General Order dated November 29, 1993.