Fruman v. Lunn

CourtUnited States Bankruptcy Court, D. Massachusetts
DecidedOctober 2, 2025
Docket19-01092
StatusUnknown

This text of Fruman v. Lunn (Fruman v. Lunn) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fruman v. Lunn, (Mass. 2025).

Opinion

UNITED STATES BANKRUPTCY COURT DISTRICT OF MASSACHUSETTS __________________________________________ ) In re: ) ) JOANNE N. LUNN, ) Chapter 7 ) Case No. 19-11275-JEB Debtor ) __________________________________________) ) PAULA FRUMAN, ) ) Plaintiff ) ) v. ) Adversary Proceeding ) No. 19-01092-JEB JOANNE N. LUNN, ) ) Defendant ) )

MEMORANDUM OF DECISION

This matter came before the Court on the Complaint filed by the Plaintiff, Paula Fruman, against the Defendant and Debtor, Joann N. Lunn. Pursuant to the Complaint, the Plaintiff seeks a determination that the debt owed by the Debtor to her is nondischargeable pursuant to Section 523(a)(2)(A), Section 523(a)(4), and Section 523(a)(6) of the Code. For the reasons set forth below, the Court finds that the debt of the Debtor to the Plaintiff is discharged. This Memorandum of Decision constitutes the findings of fact and conclusions of law pursuant to Fed. R. Civ. P. 52(a), made applicable to this proceeding by Fed. R. Bankr. P. 7052. The findings set forth in this Memorandum are based on the record as a whole and may be supported by testimony and exhibits that are not specifically cited. Any finding of fact deemed a conclusion of law is adopted as such, and vice-versa. Findings of fact may also be set forth in the Analysis section in connection with the application of the law. PROCEDURAL BACKGROUND On April 17, 2019, the Debtor commenced bankruptcy proceedings under Chapter 13 of the Code. On May 3, 2019, the case was converted to a case under Chapter 7 of the Code. The Plaintiff commenced this adversary proceeding on August 9, 2019. The Debtor was granted a

discharge of all other debts on August 19, 2019. Prior to the commencement of the bankruptcy, as more fully discussed below, the Plaintiff obtained a judgment against the Debtor in state court. The Plaintiff alleges that the debt owed by the Debtor is nondischargeable under Section 523(a)(2) based on actual fraud and false representations by the Debtor to obtain the Plaintiff’s ownership interest in a closely held corporation, JT Electronics Corp (“JTE”). She also alleges that the debt is nondischargeable under Section 523(a)(4) because there was a “defalcation” by the Debtor as an officer of JTE resulting in the destruction of JTE and the loss to Plaintiff of the benefits from JTE. Finally, the Plaintiff alleges that the debt was nondischargeable under Section 523(a)(6) due to “willful and malicious” actions of the Debtor to injure the Plaintiff through the loss of her ownership in JTE

and the destruction of the value of JTE. After discovery, the Debtor filed a motion for summary judgment, which was denied by the Court. The parties submitted a Joint Pretrial Memorandum which set forth certain stipulated facts and narrowed the issues of law and fact. The Court conducted an evidentiary trial by video on January 11, 2021, January 12, 2021, and January 13, 2021. By agreement, direct testimony was submitted by way of affidavit, with additional direct testimony at trial and the opportunity for cross-examination. In addition to the foregoing evidence, 105 exhibits were admitted at trial. JURISDICTION The Court has jurisdiction over the Complaint since it arises under Section 523 of the Bankruptcy Code. 11 U.S.C. § 523. Pursuant to Section 1334(b) of title 28, the district courts have jurisdiction of “all civil proceedings arising under title 11, or arising in or related to cases

under title 11,” subject to exceptions not applicable here. 28 U.S.C. § 1334(b). By a standing order of reference in accordance with 28 U.S.C. § 157(a), the district court in this district has referred all cases under title 11 and any proceedings arising under, arising in, or related to cases under title 11, to the bankruptcy court. See 28 U.S.C. § 157(a). The determination of the dischargeability of a debt is a core proceeding in bankruptcy. 28 U.S.C. § 157(b)(2)(I). Accordingly, this Court may hear and finally determine this matter. APPLICABLE LAW AND BURDEN OF PROOF Section 523(a) of the Code sets forth the debts that are excepted from an individual debtor’s discharge. 11 U.S.C. § 523(a). Consistent with the “fresh start” policy of the Code, exceptions to a debtor’s discharge are narrowly construed. In re Stewart, 948 F.3d 509, 520

(1st Cir. 2020). The creditor bears the burden to show that the debt “comes squarely within” an exception. In re Spigel, 260 F.3d 27, 32 (1st Cir. 2001). The standard of proof is a preponderance of the evidence. Grogan v. Garner, 498 U.S. 279, 291, 111 S. Ct. 654, 661 (1991). Section 523(a)(2) Section 523(a)(2)(A) excepts from discharge “any debt . . . for money, property, services, or an extension, renewal, or refinancing of credit, to the extent obtained by . . . false pretenses, a false representation, or actual fraud[.]” 11 U.S.C. § 523(a)(2)(A). Each of the three categories – false pretenses, false representation, and actual fraud – are separate types of misconduct, although they have overlapping elements. In re Curran, 554 B.R. 272, 284–85 (B.A.P. 1st Cir. 2016), aff’d, 855 F.3d 19 (1st Cir. 2017). To prevail on a claim for false representation, the creditor must demonstrate the following elements: 1) the debtor made a knowingly false representation or one made in reckless disregard of the truth, 2) the debtor intended to deceive, 3) the debtor intended to induce the creditor to rely upon the false statement, 4) the creditor actually relied upon the false statement, 5) the creditor’s reliance was justifiable, and 6) the reliance upon the false statement caused damage.

In re Stewart, 948 F.3d at 520 (further citations omitted). Each of the elements must be proven, or the creditor will fail to prevail. Palmacci v. Umpierrez, 121 F.3d 781, 787-88 (1st Cir. 1997). False pretenses requires the same six elements, except that the false representation is replaced by an “implied misrepresentation or a false impression created by conduct of the debtor.” In re Curran, 554 B.R. at 285 (further citations omitted). Actual fraud is broader in scope and construed in light of the traditional common law definition. In re Stewart, 948 F.3d at 521. It “consists of any deceit, artifice, trick, or design involving direct and active operation of the mind, used to circumvent and cheat another[.]” In re Lawson, 791 F.3d 214, 219 (1st Cir. 2015) (further citations omitted). It requires wrongful intent and cannot be implied by law. In re Stewart, 948 F.3d at 521.

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