Curated precedent for 11 U.S.C. Section 1192 Subchapter V discharge. Organized by doctrinal prong (discharge timing, corporate vs individual scope, Section 523(a) interaction, plan-completion mechanics) with CourtListener deep links.
How to Use This Map
Section 1192 governs discharge in Subchapter V cases. It is one of the youngest provisions in the Bankruptcy Code (effective February 19, 2020 under the Small Business Reorganization Act). Doctrine is developing actively through bankruptcy-court opinions and a small but growing number of circuit-court decisions. This map organizes the most-cited Section 1192 authorities by doctrinal prong:
Discharge Timing (interaction with Section 1191): Under 1191(a) consensual confirmation, discharge issues at confirmation under Section 1141(d). Under 1191(b) cramdown, discharge issues only after completion of plan payments (3-5 years).
Discharge Scope (Corporate vs Individual): Whether 1192's discharge encompasses the broad Chapter 11 scope or imports the narrower Chapter 7/13 scope, and whether corporate Subchapter V debtors get discharge protection from Section 523(a) nondischargeability claims.
Section 523(a) Interaction: The most-litigated open question. The text of 1192 references "any debt of the kind specified in section 523(a)" - circuits split on whether this means 523(a) exceptions apply only to individual debtors or also to corporate debtors.
Completion Mechanics: What counts as "completion" of plan payments under 1192(2), how plan modifications under Section 1193(c) interact with the discharge trigger, and what happens when the debtor satisfies the disposable-income commitment but technical payments are short.
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11 U.S.C. Section 1192: "If the plan of the debtor is confirmed under section 1191(b) of this title, as soon as practicable after completion by the debtor of all payments due within the first 3 years of the plan, or such longer period not to exceed 5 years as the court may fix, ... the court shall grant the debtor a discharge of all debts provided in section 1141(d)(1)(A) of this title, and all other debts allowed under section 503 of this title and provided for in the plan, except any debt — (1) on which the last payment is due after the first 3 years of the plan, or such other time not to exceed 5 years fixed by the court; or (2) of the kind specified in section 523(a) of this title."
Filter the Map
Click to filter by doctrinal prong. Subchapter V case law is geographically distributed and developing rapidly; circuit-by-circuit filtering is less useful here than on older statutes.
Prong:
I. Foundational Section 1192 Authority
The earliest published treatments of Section 1192 issued in 2020-2021 from bankruptcy courts confronting the new provision for the first time. These opinions remain the doctrinal anchor for discharge timing and scope analysis.
Bankruptcy Court for the District of Maryland addressed the practical consequences of the discharge-timing fork between Section 1191(a) consensual confirmation (immediate discharge under Section 1141(d)) and Section 1191(b) cramdown confirmation (deferred discharge under Section 1192 at plan completion). The opinion is one of the earliest published treatments and is widely cited as persuasive authority on the timing distinction.
Relevance to Section 1192 motions: Trepetin is the canonical reference for any brief addressing the timing question. Counsel weighing whether to push for 1191(a) consent versus proceeding to 1191(b) cramdown grounds the strategic analysis in Trepetin's discharge-timing framework.
II. Discharge Scope and Section 523(a) Interaction
Section 1192(2) excepts from discharge "any debt of the kind specified in section 523(a) of this title." Whether this language applies only to individual debtors (importing the standard 523(a) exception framework) or also to corporate debtors (a major departure from traditional Chapter 11 doctrine) is the most actively litigated open question under 1192.
4th Cir.523(a) Applies to Corporate DebtorsDeveloping
The Fourth Circuit addressed whether Section 523(a) nondischargeability exceptions apply to corporate Subchapter V debtors under 1192(2). The opinion is a leading circuit-court treatment of the corporate-discharge-scope question and is cited by bankruptcy courts in other circuits considering the same issue. Counsel should pull the most current opinion and confirm the holding before relying.
Relevance to Section 1192 motions: For corporate Subchapter V debtors, Cleary Packaging is the leading circuit-court authority on whether 523(a) exceptions survive 1192 discharge. The doctrinal split it surfaces drives strategy on plan structuring and creditor objections.
Section 1192's reference to "all debts provided in section 1141(d)(1)(A)" pulls the standard Chapter 11 discharge scope into Subchapter V cramdown cases. Section 1141(d)(1)(A) provides for discharge of any debt that arose before confirmation, except as otherwise provided.
Relevance to Section 1192 motions: Cited in any brief addressing the scope question - the operative interaction is between 1192 (Subchapter V cramdown discharge), 1141(d)(1)(A) (Chapter 11 scope reference), and 523(a) (nondischargeability exceptions).
III. Discharge Timing (1191(a) Immediate vs 1191(b) Deferred)
The discharge-timing fork is the most strategically consequential element of Section 1191/1192 doctrine. Under 1191(a) consensual confirmation, the debtor receives an immediate discharge at confirmation under 1141(d). Under 1191(b) cramdown, the debtor receives no discharge until completion of plan payments under Section 1192.
See Foundational section above. Trepetin's timing analysis is the most-cited treatment of the immediate-vs-deferred discharge distinction.
Relevance: The timing question affects every Subchapter V case where consent is uncertain. Trepetin is the analytic frame used to argue for or against pushing toward 1191(a) acceptance.
What counts as "completion" under Section 1192? Section 1192 ties discharge to the debtor's "completion ... of all payments due within the first 3 years of the plan, or such longer period not to exceed 5 years as the court may fix." Plan modification under Section 1193(c) can adjust the payment schedule mid-stream, raising questions about how modifications interact with the discharge trigger.
Section 1192 conditions discharge on completion of payments due in the first 3-5 years. Section 1192(1) excepts debts "on which the last payment is due after the first 3 years of the plan, or such other time not to exceed 5 years fixed by the court" - meaning long-tail debts (e.g., mortgages amortizing past the plan period) survive discharge. Section 1192(2) excepts debts "of the kind specified in section 523(a)."
Relevance to Section 1192 motions: Counsel briefing a discharge order under 1192 must address (1) whether all required payments have been made, (2) which debts fall under the 1192(1) long-tail exception, and (3) which debts fall under the 1192(2) Section 523(a) exception.
Every case on this page is cited from published reporters where available, and links to CourtListener's canonical reporter URL or a CourtListener search that surfaces the matching opinion. Cases marked "Verified" have been cross-checked against published reporter copies. Cases marked "Developing" reflect the reality that Subchapter V doctrine is still maturing through bankruptcy-court and circuit-court opinions.
Where a citation links to a CourtListener search rather than a direct opinion URL, that is because the underlying opinion is recent and the search returns the matching docket. Click through and confirm by case name and year.
Note: This page is a research index, not a filing. Subchapter V case law is at an early developmental stage; what counts as the leading authority will shift as more circuit courts begin issuing precedential opinions on Section 1192. Every attorney or pro se party preparing a discharge motion or objection should run a current CourtListener search and read the full opinion before relying on any cite below.