Link v. Mauz (In re Mauz)

Case Type:
Case Status:
16-1250 (3rd Circuit, Jan 13,2017) Published
District Court’s order affirming the Bankruptcy Court’s decision holding that a $217,100 debt owed to the Appellees was not dischargeable under 11 U.S.C. § 523(a)(6) was affirmed.
Procedural context:
Appeal to Third Circuit Court of Appeals from District Court's ruling affirming Bankruptcy Court decision finding debt non-dischargable based upon a "willful and malicious" injury under section 523(a)(6) of the Bankruptcy Code.
Mauz and the Links, who were property owners. Over the years, Mauz filed ten complaints against the Links in state court. Each was either dismissed, withdrawn, or resulted in a finding of not guilty. Mauz also made over thirty complaints against the Links with the local police department and various municipal offices. None of these complaints resulted in charges against the Links. In an apparent attempt to halt Mauz’s persistent conduct, the Links sued Mauz in the Court of Common Pleas of York County for intentional infliction of emotional distress. After a bench trial, the Links were awarded $217,000 in damages. Mauz countered by filing a Chapter 7 petition for voluntary bankruptcy. While Mauz’s bankruptcy proceedings were pending, the Links commenced an Adversary Proceeding against Mauz, in which they argued that Mauz could not discharge the state court judgment because it was based on a finding of intentional infliction of emotional distress. The Bankruptcy Court and the District Court agreed with the Links and held that Mauz’s debt to the Links was not dischargeable under 11 U.S.C. § 523(a)(6). Mauz then appealed to the Third Circuit Court of Appeals. The Third Circuit noted that “an injury is willful and malicious under the Code only if the actor purposefully inflicted the injury or acted with substantial certainty that the injury would result.Her the District Court determined that Mauz’s “outrageous” number of “spurious” complaints caused emotional and physical injury to the Links and their property and that Mauz had acted willfully with the purpose of injuring the Links. In affirming the Circuit Court stated : "Having reviewed the record, we agree that it is a waste of judicial resources to spill any further ink on Mauz’s meritless contentions, and we will therefore affirm the judgment of the District Court substantially for the reasons set forth in the Court’s well reasoned opinion."

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