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In re Taylor

United States Court of Appeals for the Tenth Circuit
737 F.3d 670 (2013)


Facts

Eloisa Taylor (defendant) and Matthew Taylor (plaintiff) divorced. The circuit court ordered Matthew to pay Eloisa $2,500 per month in spousal support until Eloisa remarried. Eloisa began living with another man, and Matthew moved to end his spousal support due to Eloisa’s marriage-like relationship. The circuit court granted Matthew’s motion retroactively, entering a judgment of over $50,000 against Eloisa. Eloisa filed for Chapter 7 bankruptcy in the United States Bankruptcy Court for the District of New Mexico. Matthew filed a complaint claiming that the $50,000 overpayment debt based on the circuit court’s judgment was not dischargeable in bankruptcy. The bankruptcy court found that the debt qualified as dischargeable as a domestic support obligation because the debt was not for the support of Matthew. However, the bankruptcy court did not discharge the debt because the debt arose in connection with a divorce proceeding. The bankruptcy appellate panel affirmed. Both parties appealed. Eloisa argued the absurdity doctrine should prevent the court from applying the plain language of the Bankruptcy Code because it ran counter to the drafters’ intent.

Rule of Law

Issue

Holding and Reasoning (Briscoe, C.J.)

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