In re: Brian John Phillips and Amanda Elizabeth Phillips

CourtUnited States Bankruptcy Court, D. Colorado
DecidedJune 2, 2026
Docket23-01157
StatusUnknown

This text of In re: Brian John Phillips and Amanda Elizabeth Phillips (In re: Brian John Phillips and Amanda Elizabeth Phillips) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Brian John Phillips and Amanda Elizabeth Phillips, (Colo. 2026).

Opinion

IN THEF OURN ITTHEED DSITSATTREICST B OAFN KCROULPOTRCAYD OCO URT The Honorable Michael E. Romero

In re: Case No. 23-11114 MER Brian John Phillips and Amanda Elizabeth Phillips Chapter 7

Debtors.

Attorneys Title Guaranty Fund, Inc. Adversary No. 23-01157 MER

Plaintiff,

v.

Brian John Phillips

Defendant.

ORDER RE: PLAINTIFF’S COMPLAINT

This matter comes before the Court following a trial on Plaintiff Attorneys Title Guaranty Fund, Inc.’s (“ATGF”) Complaint. At issue is whether a state court judgment ATGF obtained against Debtor/Defendant Brian Phillips (“Phillips”) is excepted from Phillips’ discharge pursuant to 11 U.S.C. § 523(a)(6).

BACKGROUND

ATGF is a title insurance underwriting company. Phillips joined ATGF as its vice president and general counsel in February 2017. He was promoted to CEO in May 2018 and remained ATGF’s CEO until June 2020. In or around December 2018, Phillips learned that Title One, a national title and escrow company, was interested in selling its business to ATGF. Phillips felt the acquisition would be a good opportunity for ATGF to expand its business and generate additional revenue. As such, Phillips discussed ATGF acquiring Title One with ATGF’s chairman of the board, Maurizio Romanin (“Romanin”). Phillips and Romanin discussed the Title One purchase for several months. However, Phillips believed that Romanin wasn’t interested in purchasing Title One, and that any hope for a deal between the two companies was dead. Eventually, Phillips, along with his wife and another ATGF employee, Devin Storms (“Storms”), personally purchased Title One. Phillips became Title One’s CEO while he was still ATGF’s CEO. Romanin didn’t become aware that Phillips had purchased Title One or was its CEO until after Phillips left ATGF. proprieWtarhyil eu nPdheilrlwiprsit iwnga ss oAfTtwGaFr’es, CEEPOIC, .i sAsTuGesF ’asr oasgee nretsg aarred ianlgl rtehqeu uirseed otof AuTsGe FE’Ps IC; however, a majority of them do not like using it. In an effort to address this issue, Phillips implemented Agent Plus/the KSS Initiative. Through the KSS Initiative, ATGF’s agents would enter underwriting information into the software of their choice, and KSS, a third-party company located in India, would enter the data from the agent’s chosen software into EPIC that night. However, ATGF encountered several problems with the KSS Initiative, including a COVID-19 pandemic-related backlog of data to be entered into EPIC. Disputes also arose about whether Phillips was making accurate representations to ATGF’s board and other regulatory agencies regarding the timeliness of the data entry into EPIC.

In April of 2020, Phillips decided to leave ATGF for one of its competitors, First National Title Insurance Company (“FNTIC”). While discussing his own job opportunity with FNTIC, Phillips identified two of ATGF’s employees, Storms and Kim Whitlock (“Whitlock”), as potential employees to bring over to FNTIC. For several months, Phillips facilitated conversations between himself, FNTIC, Storms, and Whitlock regarding salary, commissions, and other potential opportunities. On June 4, 2020, Phillips sent an email to FNTIC stating that he, Storms, and Whitlock accepted FNTIC’s offers of employment and could start working at FNTIC in late June or possibly sooner. Phillips, Storms, and Whitlock all left ATGF around the same time and began working at FNTIC.

Following Phillips’ departure, ATGF commenced litigation against him in the Denver County District Court (“State Court”), asserting a single claim for breach of fiduciary duty (“State Court Case”).1 Before the State Court Case could proceed to trial, Phillips filed the underlying bankruptcy case, and ATGF commenced the instant adversary proceeding pursuant to § 523(a)(4) and (a)(6). Phillips filed a counterclaim for defamation. On September 28, 2023, Phillips filed a Motion to Stay Proceedings Under Doctrine of Discretionary Abstention (“Motion to Stay”), which ATGF opposed. Following a hearing on the matter, the Court granted the Motion to Stay. The parties returned to State Court, and a jury trial was held. The jury considered ATGF’s claim for breach of fiduciary duty based on three different alleged breaches: (1) Phillips’ inducing ATGF employees to leave ATGF for a competitor; (2) Phillips usurping ATGF’s opportunity to purchase Title One and operating Title One in conflict with ATGF’s interests; and (3) Phillips’ lying to ATGF executives about the use of EPIC by ATGF’s agents. Following the trial, the jury returned a verdict in ATGF's favor and awarded it damages (“Jury Verdict”). Phillip’s counterclaim for defamation was also resolved at trial via a motion for a directed verdict, which was granted in favor of ATGF. The State Court entered judgment in accordance with the Jury Verdict on October 11, 2024 (“State Court Judgment”). The parties then returned to this Court to determine whether the State Court Judgment is excepted from Phillips’ discharge. On April 2, 2025, ATGF filed a motion for summary judgment. Phillips filed a response and cross- motion for summary judgment. On August 22, 2025, the Court entered an order

1 District Court, Denver County, Colorado Case No. 2021CV30630. gthrea nCtionugr tt hfoeu mndo ttiohna tf othre s uJumrmy Vareyr djuicdtg amnedn St tiant ep aCrto aunrtd J duedngyminegn ti th ina dp aar pt.re cInlu psaivreti ceufflaerc,t on the issues of causation and damages because the jury found that ATGF was injured and that Phillips caused the injury. However, the Court determined issues regarding Phillip’s intent had not been resolved in the State Court Case, and that they needed to be resolved at trial in this proceeding.3 Prior to trial, the parties submitted joint testimony designations from the State Court trial transcripts, as well as exhibits.4 The Court conducted a trial on ATGF’s complaint on January 8, 2026. At the trial, the Court admitted several exhibits and heard testimony from Phillips.

ANALYSIS

A. Intent Under 11 U.S.C. § 523(a)(6)

The only issue before the Court is whether Phillips had the requisite intent to find the State Court Judgment nondischargeable under § 523(a)(6). A claim under § 523(a)(6) requires a showing of an intentional act by the defendant that was done with the intent to harm.5 In other words, Phillips’ conduct must have been both “willful” and “malicious.” Willfulness “takes a deliberate or intentional injury, not merely a deliberate or intentional act that leads to injury.”6 Courts have recognized two ways of establishing willful conduct. The debtor must either “desire to cause the consequences of his act or believe the consequences are substantially certain to result from it.”7 The latter “substantial certainty” test is not an objective test.8 Instead, willfulness under both standards is a wholly subjective test dependent on the debtor's state of mind.9 The second element refers to proof of a malicious injury, distinct from willfulness. Malicious injury requires evidence of the debtor’s motives. To be malicious, the debtor must have “acted with a culpable state of mind vis-à-vis the actual injury caused to the creditor.”10

2 The Court also denied Phillips’ cross motion for summary judgment.

3 At the time ATGF filed its motion for summary judgment, it also maintained a claim pursuant to 11 U.S.C. § 523(a)(4), which was not addressed in its summary judgment motion. As such, the Court also found that the § 523(a)(4) claim would be decided at trial. However, ATGF withdrew its § 523(a)(4) claim prior to trial.

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Bluebook (online)
In re: Brian John Phillips and Amanda Elizabeth Phillips, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-brian-john-phillips-and-amanda-elizabeth-phillips-cob-2026.