Issue link: https://mbozikis.ufcontent.com/i/1422521
220 (vii) educational loans made, insured or guaranteed by a governmental unit or scholarships or stipends obligated to be paid (unless excepting such debt would impose an undue hardship on the debtor and its dependents); (viii) any debt for death or personal injury caused by the debtor's illegal operation of a motor vehicle, vessel or aircraft while intoxicated; (ix) any debt for restitution or a criminal fine included in a sentence imposed upon the debtor's conviction of a crime; or (x) any debt for restitution or damages awarded in a civil action against the debtor as a result of willful or malicious injury by the debtor that caused personal injury or death to an individual. 11 U.S.C. § 1328(a). Additionally, a Chapter 13 debtor is not discharged from any postpetition consumer debt for property or services necessary for the debtor's performance under the plan if prior approval by the trustee of the debtor's incurring of such debt was practicable, but was not obtained. 11 U.S.C. § 1328(d). The court may grant a so-called "hardship discharge" to a debtor that has not completed payments under the plan only if (i) "the debtor's failure to complete such payments is due to circumstances for which the debtor should not justly be held accountable," (ii) the value, as of the plan's effective date, of property actually distributed under the plan on account of each allowed unsecured claim is not less than the amount that would have been paid on such claim in a hypothetical Chapter 7 liquidation of the debtor, and (iii) modification of the plan is not practicable. 11 U.S.C. § 1328(b). Most courts take a fairly strict view of the hardship discharge and limit its application to compelling circumstances. See, e.g., In re White, 126 B.R. 542 (Bankr. N.D. Ill. 1991). Other courts take a more lenient approach and allow a hardship discharge "due to economic circumstances