A drawback of student loans is that a debtor must show “undue hardship” to discharge them in bankruptcy. An advantage of student loans is that most of them may be repaid using income-driven repayment (“IDR”) plans, under which the debtor can satisfy the obligation by paying a share of...

To interpret the open-ended phrase “undue hardship,” courts must look not just to the goals of the nondischargeability provision in isolation, but also to the broader purposes of Title IV of the Higher Education Act (HEA), the statutory scheme governing federal student loans. Over 90 percent...