What do you need for an adversary proceeding to discharge student loans for hardship reasons?

Undue hardship' dismissals of student loan(s) decisions are generally based on criteria of the U.S. Court of Appeals 2nd Circuit, Marie Brunner, Appellant vs. N.Y. State H.E.S.C. Very seldom will a lower court allow the discharge of student loans. The exception could be,a disability which will not allow the loan holder to ever earn/have sufficient income for repayment.

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