Nitka v. Department of Education

CourtCourt of Appeals for the Tenth Circuit
DecidedApril 23, 2021
Docket20-1270
StatusUnpublished

This text of Nitka v. Department of Education (Nitka v. Department of Education) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nitka v. Department of Education, (10th Cir. 2021).

Opinion

FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT April 23, 2021 _________________________________ Christopher M. Wolpert Clerk of Court In re: GORDON NITKA,

Debtor.

------------------------------

GORDON BEECHER NITKA,

Plaintiff - Appellant,

v. No. 20-1270 (BAP No. CO 20-002) DEPARTMENT OF EDUCATION,

Defendant - Appellee. _________________________________

ORDER AND JUDGMENT* _________________________________

Before MORITZ, BALDOCK, and EID, Circuit Judges. _________________________________

Gordon Nitka initiated an adversarial proceeding in bankruptcy court against

the Department of Education (“DOE”), seeking discharge of approximately $200,000

in law school student loans based on “undue hardship” under 11 U.S.C. § 523(a)(8).

* After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. The bankruptcy court granted summary judgment to DOE, and the Bankruptcy

Appellate Panel (“BAP”) affirmed. Nitka appeals pro se from the BAP’s decision.1

Exercising jurisdiction under 28 U.S.C. § 158(d)(1), we affirm.

BACKGROUND

Nitka graduated from Colorado College in 2005 with degrees in English and

Biology. During college, he worked as a host for the school’s administration, a

physiology and anatomy tutor, a surgical paraprofessional, and a bartender and server

at a resort. After graduating, he continued working at the resort before taking a

position as the co-director of a hospitality center at the 2006 Winter Olympics in

Italy. Upon returning to Colorado, he resumed his jobs at the resort and also began

working in nightclubs, first as security and later as a manager.

In 2010, Nitka enrolled at Phoenix School of Law, later renamed the Arizona

Summit Law School. He financed his education with student loans, executing two

master promissory notes. While in school, he held several paid positions, including

in the legal field and as a fitness coach. After graduating, he worked as a contract

employee at a law firm, earning $25 per hour as a law clerk and rising to the rank of

1 “[W]e generally construe pro se pleadings liberally” but have not “extend[ed] the same courtesy to . . . licensed attorney[s].” Comm. on the Conduct of Att’ys v. Oliver, 510 F.3d 1219, 1223 (10th Cir. 2007) (internal quotation marks omitted). The parties dispute whether, and to what extent, we should liberally construe Nitka’s filings, considering he is a law school graduate but not a licensed attorney. Because it does not affect the outcome of the case, we liberally construe Nitka’s filings. But he still must “follow the same rules of procedure that govern other litigants,” and we “cannot take on the responsibility of serving as [his] attorney in constructing arguments and searching the record.” Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836, 840 (10th Cir. 2005) (internal quotation marks omitted). 2 firm director. He took the Arizona bar exam twice but did not pass. To supplement

his income, Nitka (1) continued fitness coaching until November 2015, earning up

to $90 per hour; (2) served as an advisor to a start-up fitness company, earning

equity compensation; and (3) worked twenty to thirty hours per week selling

commission-based insurance for MassMutual from August 2014 to January 2018.

In May 2018, the law firm terminated Nitka’s employment. He has since been

unemployed, with the exception of earning approximately $3,000 over the course of a

couple months as a roofing salesman. He unsuccessfully applied for several jobs and

testified in May 2019 that he had ceased submitting applications, instead focusing his

time on (1) building a mobile phone application for the restaurant industry, and

(2) converting a bus into a vacation rental that he will park near ski resorts. He lives

rent-free with his mother and has about $32,000 in retirement accounts. When he has

income, he spends about $200 per month on food and $60 on a cell phone plan.

As of November 2019, Nitka’s student loan debt was $209,716.48. He made

no payments on the loans in 2013 and obtained a deferral for most of 2014. In June

2015, he began participating in an income-driven repayment program that reduced his

monthly obligation. Still, he did not make any payments in 2015, despite earning

$61,901, with an adjusted gross income of $39,156 and taxable income of $28,856.

In 2016, he made six payments of $21.82, totaling $130.92, although his gross

income was $83,000, with taxed Social Security earnings of $54,643. He earned

$31,180 in 2017 and made five payments of $21.82, totaling $109.10. He made no

payments in 2018, when he earned $8,381, with an adjusted gross income of $8,010.

3 Nitka has paid a total of only $240.02, but DOE has asserted he remains eligible for

an income-based program, under which his balance would be forgiven after 25 years.

In July 2018, Nitka, then 36 years old, filed a petition under Chapter 7 of the

Bankruptcy Code and an adversary proceeding to have his loans discharged. After

several discovery disputes, DOE moved for summary judgment. Nitka opposed the

motion and moved for sanctions, claiming DOE made factual misrepresentations.

The bankruptcy court denied Nitka’s motion for sanctions and granted DOE’s motion

for summary judgment. The BAP affirmed, and Nitka appealed to this court.

DISCUSSION

“In our review of BAP decisions, we independently review the bankruptcy

court decision,” In re Albrecht, 233 F.3d 1258, 1260 (10th Cir. 2000), assessing legal

conclusions de novo and factual findings for clear error, see Borgman v. Dunckley

(In re Borgman), 698 F.3d 1255, 1259 & n.5 (10th Cir. 2012). Nitka raises several

challenges to the bankruptcy court’s judgment. None are persuasive.

I. Procedural Rulings Prior to DOE Moving for Summary Judgment

First, Nitka contends the bankruptcy court erred in granting DOE’s motion

under Fed. R. Civ. P. 37 to prohibit him from using exhibits or witnesses, other than

himself, at trial due to his failure to fully and timely comply with the scheduling

order’s requirements for serving trial exhibits. As the BAP observed, the bankruptcy

court considered Nitka’s exhibits in ruling on DOE’s motion for summary judgment.

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