Joseph Mauz v., 672 F. App'x 176

Mauz and William & Kimberly Link were neighboring property owners who engaged in prolonged hostile interactions.
Over several years Mauz filed 10 state-court complaints against the Links (all dismissed, withdrawn, or resulted in not guilty) and made 30+ complaints to police/municipal offices without charges.
The Links sued Mauz in York County for intentional infliction of emotional distress; after a bench trial they were awarded $217,000 in damages.
Mauz filed a Chapter 7 bankruptcy petition and the Links brought an adversary proceeding seeking a determination that the judgment was nondischargeable under 11 U.S.C. § 523(a)(6).
The Bankruptcy Court held the debt nondischargeable as arising from a willful and malicious injury; the District Court affirmed.
Mauz appealed to the Third Circuit, which affirmed the District Court’s judgment without re-litigating the factual record.

Issue	Plaintiff's Argument (Mauz)	Defendant's Argument (Links)	Held
Whether the state-court judgment arises from a "willful and malicious" injury under 11 U.S.C. § 523(a)(6)	The judgment should be dischargeable; Bankruptcy Court erred in finding willful/malicious conduct	Judgment resulted from Mauz’s purposeful, repeated, and outrageous conduct intended to harm the Links	Affirmed: debt nondischargeable — Mauz acted willfully and maliciously

In re Winstar Commc’ns, Inc., 554 F.3d 382 (3d Cir.) (standards for appellate review of bankruptcy decisions)
In re Michael, 699 F.3d 305 (3d Cir.) (standards for reviewing bankruptcy factual and legal determinations)
In re Fruehauf Trailer Corp., 444 F.3d 203 (3d Cir.) (standard for overturning factual findings)
In re Gerhardt, 348 F.3d 89 (5th Cir.) (characterizing dischargeability as a question of law)
In re Conte, 33 F.3d 303 (3d Cir.) (definition of "willful" under § 523(a)(6))
In re Braen, 900 F.2d 621 (3d Cir.) (burden of proof for exception to discharge)