In a ruling that promises to make it much more difficult for bankruptcy
debtors to win forgiveness of their student loans on "undue hardship"
grounds, the 3rd U.S. Circuit Court of Appeals has ruled that such debtors
must prove that they made good faith efforts to repay the loans over the
"entire" period from the first due date of the loans to the bankruptcy
The court's unpublished per curiam opinion in Pelliccia v. U.S. Department
of Education is a significant narrowing of the court's 1995 decision that
established the undue hardship test, Pennsylvania Higher Education
Assistance Agency v. Faish.