In re Crawford
United States Court of Appeals for the Seventh Circuit
324 F.3d 539 (2003)
Crawford (debtor) owed nondischargeable child support debt to a county along with debts to the IRS and trade creditors; his original plan proposed paying the county debt in full over three years and only 3-6% to other creditors contingent on winning a separate IRS dispute, but after losing that dispute he amended the plan to pay two-thirds of the county debt and nothing at all to other unsecured creditors, when a plan without such preferential classification would have paid all creditors roughly 32 cents on the dollar. The bankruptcy court rejected the plan as unfairly discriminatory, the district court affirmed, and Crawford appealed.
Whether a Chapter 13 plan that proposes to pay a significant proportion of a debt owed for nonpayment of child support but nothing to other nonpriority unsecured creditors discriminates unfairly against those other creditors.