Zaepfel v. Zaepfel, 665 B.R. 58

Andrea and David Zaepfel were married and later divorced; during the marriage, David used funds from their son Nolan's Uniform Gift to Minors Act (UTMA) account for non-beneficiary purposes.
A Florida divorce judgment ordered David to reimburse $139,696.82 to Nolan’s UTMA account, with specific repayment terms over five years.
David filed for Chapter 7 bankruptcy, seeking to discharge this debt.
Andrea (ex-spouse) and Nolan (son) filed an adversary proceeding, arguing the debt is nondischargeable under 11 U.S.C. § 523(a)(15).
Plaintiffs moved for summary judgment, asserting no material factual dispute.
The only legal question was whether § 523(a)(15) covers obligations to adult children, as Nolan was not a minor at the time of the divorce.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether debt owed to an adult child under a divorce judgment is nondischargeable under § 523(a)(15)	Yes, the statute applies to debts owed to any child, regardless of age	No, "child" under § 523(a)(15) means only minor children; debt is not for child support	Court held the statute is not limited to minors; debt to Nolan is nondischargeable
Whether Plaintiffs have standing under § 523(a)(15)	Both Nolan (child) and Andrea (ex-spouse) have standing	Only spouse, former spouse, or minor child have standing; Nolan is not a minor	Both have standing as "child" isn't age-restricted in statute

Jenkins v. Jenkins, 202 B.R. 102 (Bankr. C.D. Ill. 1996) (addressing § 523(a)(15) scope for property settlement nondischargeability)
Richardson v. Edwards, 127 F.3d 97 (D.C. Cir. 1997) (college expenses owed to adult child can be a nondischargeable support obligation)
Harrell v. Sharp (In re Harrell), 754 F.2d 902 (11th Cir. 1985) (obligation to pay for adult child's education nondischargeable)
Boyle v. Donovan, 724 F.2d 681 (8th Cir. 1984) (nondischargeability of college support for non-minor child)