Summary

The bankruptcy court denied summary judgment to both the debtor and MOHELA/Navient in a closely watched dispute over whether a private student loan qualifies as a "qualified education loan" under § 523(a)(8)(B). The court held that genuine issues of material fact remain regarding whether the loan exceeded the debtor's actual cost of attendance, an issue that could determine whether the debt was ever excepted from discharge in the first place.

Available at: https://scholarlycommons.law.northwestern.edu/nulr/vol120/iss5/1

Available at: Power Failure: Rising Energy Debt Is Climbing into the Middle Class[/] (The Century Foundation, July 21, 2026)

Available at: https://www.newyorkfed.org/medialibrary/interactives/householdcredit/data/pdf/HHDC_2026Q1

Available at:  

https://www.journaloffreespeechlaw.org/hampson.pdf
http://blogs.law.ox.ac.uk/oblb/blog-post/2025/09/defamation-bankruptcy-pipeline-united-states-and-around-world

Available at: Post-Petition Wages and Attorneys' Fees in a Post-Harris World: Protecting Debtors' Counsel from Going Unpaid   (ABI membership required)

Available at: https://scholarlycommons.law.northwestern.edu/nulr/vol120/iss5/6

June 18, 2026

Available at SSRN: https://ssrn.com/abstract=6954401

Abstract:

Commentary

Professor Steinberg correctly identifies a genuine problem: bankruptcy courts have struggled for years with determining how much factual detail is necessary before a proof of claim should enjoy Rule 3001(f)'s prima facie presumption of validity. His proposed solution is a thoughtful step toward greater national uniformity.

The article, however, is also remarkably Chapter 11-centric.