In an adversary proceeding seeking non-dischargeability, under 11 U.S.C. § 523(a)(6), of a state court award of compensatory and punitive damages against debtor, the court previously ruled that debtor was collaterally estopped from re-litigating both the non-dischargeability of the compensatory damages and that the punitive damage award was based on "willful and malicious injury" of plaintiff. Four minority arguments to the effect that § 523's non-dischargeability provisions are inapplicable to punitive damages were considered and rejected by the court. In doing so, the court noted that it had previously held, along with a minority of other courts, that punitive damage awards were subject to discharge. However, the court felt compelled to reevaluate that position after the U.S. Supreme Court, in Grogan v. Garner, 498 U.S. 279 (1991), included punitive damages in the amount determined to be non-dischargeable under § 523(a)(2). The bankruptcy court concluded that punitive damages may be non-dischargeable under § 523(a)(6), and that the punitive damage award against debtor in the case before it was non-dischargeable.