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Opinion 459

Case Name: 

State Farm Fire and Casualty Company v. Edie (In re Edie)

Judge: 
Judge Boulden
Date: 
Sep-7-2004
Case Number(s): 
03-2449
Status: 

PUBLISHED

Body: 

Plaintiff insurance company filed a nondischargeability action under 11 U.S.C. §523(a)(6) to except a California state court default judgment from the debtor's discharge. The debtor admitted she intentionally started a fire in the home of the plaintiff's insured but claimed her intent was limited to a desire to burn shirts hanging in a closet, not to destroy the entire home. The debtor further defended her actions by claiming she was not able to foresee the potential and likely consequences of her conduct due to a mental defect or illness from which she suffered at the time she started the fire. The plaintiff filed a summary judgment motion claiming the debtor's admission of intent to start the fire and application of collateral estoppel to the previously obtained default judgment left no material issue of fact to be determined at trial. The court granted summary judgment and determined California's collateral estoppel doctrine applies to default judgments and barred the debtor from presenting new defenses not raised in the state court litigation. The court also found that even absent the application of collateral estoppel, the debtor's admission of intentionally igniting a fire to the plaintiff's insured's property amounts to a willful and malicious injury to the plaintiff and the defendant did not offer any evidence to support a defense of mental impairment.

Internal Ref: 
Opinion 459
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