McClendon v. Springfield (In Re McClendon)
765 F.3d 501
| 5th Cir. | 2014Background
- Defamation judgment for Springfield against McClendon for $341,000; McClendon filed Chapter 11 bankruptcy May 11, 2011.
- Springfield sued in Texas state court; evidence supported defamation finding and damages.
- Springfield's creditor claim arises in McClendon's bankruptcy; Springfield seeks nondischargeability under §523(a)(6).
- Bankruptcy court held debt nondischargeable as willful and malicious injury; district court affirmed.
- McClendon confirmed a Chapter 11 plan on January 30, 2012; this appeal challenges the dischargeability ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether McClendon's statements satisfy willful and malicious injury under §523(a)(6). | Springfield contends statements were intentional causes of harm. | McClendon claims honest belief in truth prevents willful injury. | Yes; willful and malicious injury established. |
| Whether the bankruptcy court impermissibly shifted the burden of proof. | Court properly applied burden; no improper presumption. | Existence of burden shifting disputed; context matters. | Waived issue; not preserved on appeal. |
| Whether the bankruptcy court could independently find willfulness despite the state-court verdict. | Independent inquiry appropriate given §523(a)(6). | Findings must stem from state court if determinative. | Bankruptcy court may conduct independent factfinding. |
| WhetherCONTEXT supports considering the context of statements in assessing harm. | Context shows substantial certainty of harm. | Context argument insufficient to negate willfulness. | Context considered; still supports substantial certainty. |
Key Cases Cited
- Grogan v. Garner, 498 U.S. 279 (1991) (proof standard for nondischargeability §523(a)(6))
- In re TransTexas Gas Corp., 597 F.3d 298 (5th Cir. 2010) (clear error standard; de novo law on §523(a)(6))
- In re Jay, 432 F.3d 323 (5th Cir. 2005) (context of findings; standard of review for factual conclusions)
- Kawaauhau v. Geiger, 523 U.S. 57 (1998) (§523(a)(6) requires actual intent to cause injury; not mere negligence)
- Miller, 156 F.3d 598 (5th Cir. 1998) (willful and malicious injury defined as substantial certainty or subjective intent to harm)
- Williams, 337 F.3d 504 (5th Cir. 2003) (relationship of intent and substantial certainty in willful injury)