Parker v. Dept. of Education/NelNet

CourtUnited States Bankruptcy Court, D. New Mexico
DecidedApril 16, 2025
Docket24-01008
StatusUnknown

This text of Parker v. Dept. of Education/NelNet (Parker v. Dept. of Education/NelNet) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parker v. Dept. of Education/NelNet, (N.M. 2025).

Opinion

UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW MEXICO In re: ROSE MARIE PARKER, No. 24-10155-j7 Debtor.

ROSE MARIE PARKER, Plaintiff, v. Adversary No. 24-1008-j U.S. DEPARTMENT OF EDUCATION, NELNET SERVICING LLC,

Defendants. MEMORANDUM OPINION AND ORDER ON A MOTION TO COMPEL DISCLOSURE OF MEDICAL INFORMATION ADDRESSING HIPAA AND THE EFFECT OF DOE’S STUDENT LOAN ATTESTATION GUIDELINES

THIS MATTER is before the Court on the Defendant U. S. Department of Education’s Motion to Compel Plaintiff to Respond to Discovery Requests (“Motion to Compel” – Doc. 40). The U.S. Department of Education (“DOE”) served discovery in connection with Plaintiff Rose Marie Parker’s claim seeking a student loan hardship discharge under 11 U.S.C. § 523(a)(8),1 requesting production of medical records and answers to interrogatories relating to Ms. Parker’s medical condition.2 Plaintiff opposes the Motion to Compel. Plaintiff contends that no additional discovery responses are required because her sworn statement “detailing the limitations caused by a chronic condition and how these limitations affect her ability to maintain stable employment” comports with the attestation procedure set

1 References to “§” are to title 11 of the United States Code. 2 References to “medical condition(s),” “health condition(s),” or “medical information” refers to both physical and mental health. References to “medical records” refers to both physical and mental health medical records. forth in DOE’s November 2022 Guidance on Student Loan Discharge in Bankruptcy (“DOE Guidance”)3 under which the DOE does not require production of medical records or disclosure of other medical information. See Plaintiff’s Response in Opposition to Defendant’s Motion to Compel Discovery (“Response” – Doc. 41). Plaintiff contends that submission of a “functional impact statement” and existing financial records to the DOE are sufficient under the DOE

Guidance for DOE to recommend discharge of Plaintiff’s student loans under § 523(a)(8)’s undue hardship standard without the need for her to provide further responses to DOE’s interrogatories or to produce medical records. Id. Plaintiff also asserts that HIPAA (defined below) and the physician-patient privilege, as well as confidentiality and privacy concerns, protect her from having to produce any medical records or other medical information to DOE. For the reasons explained below, the Court will grant the Motion to Compel, in part, and order Plaintiff to provide supplemental discovery requests as set forth in this Order. PROCEDURAL HISTORY Plaintiff, proceeding pro se, initiated this adversary proceeding on March 11, 2024, by

filing an Adversary Complaint (“Complaint”) seeking to discharge student loans under § 523(a)(8). (Doc. 1).4 Plaintiff asserts that repayment of her student loans would impose an undue hardship on herself and her family based on her “[c]urrent physical as well as mental health issues that have impacted [her] ability to work or earn income (due to these have difficulty maintaining employment on long term basis.” Complaint, ¶ 5.a. The Court held a scheduling

3 See Guidance for Department Attorneys Regarding Student Loan Bankruptcy Litigation, dated November 17, 2022, found at https://www.justice.gov/civil/file/1553726/dl?inline=, last visited March 26, 2025. 4 The total amount of Debtor’s scheduled student loan debt is $130,055.00. See Case No. 24-10155-j7, Schedule E/F (Doc. 1, p. 44). conference on July 1, 2024, and fixed a discovery completion deadline of October 29, 2024. (Doc. 18). DOE served discovery requests on Plaintiff on July 5, 2024. (Doc. 19). On July 16, 2024, Plaintiff filed a letter requesting the discharge of her student loan debt (“Correspondence and Request for Court Intervention” – Doc. 21), in which Plaintiff a) describes the DOE’s internal process for evaluating student loan dischargeability claims, b) provides an

employment history from January 2016 through the present, and c) raises concerns about the sensitive nature of her medical information, privacy, and confidentiality. DOE filed a response to the Correspondence and Request for Court Intervention (Doc. 23), and Plaintiff filed additional correspondence in reply to DOE’s response (Doc. 25). The Court denied Plaintiff’s request for Court intervention and assistance, and took no further action with respect to the correspondence, pointing out that a) the Court does not oversee DOE’s internal processes for evaluating student loan dischargeability, b) Plaintiff is not required to participate in the DOE’s attestation process, and c) Plaintiff will bear the burden of proving dischargeability of her student loans under § 523(a)(8) if she is unable to reach a settlement with

DOE prior to trial. (Doc. 26). Plaintiff filed additional correspondence (Doc. 31), again outlining the DOE’s streamlined procedures for evaluating student loan dischargeability and requesting the Court to deny DOE’s request for discovery of additional medical records. In a Scheduling Order entered October 2, 2024, the Court fixed a deadline of October 25, 2024, for Plaintiff to respond to DOE’s outstanding discovery requests. (Doc. 29). DOE filed a motion to dismiss this adversary proceeding based on Plaintiff’s failure to respond to DOE’s discovery requests. (Doc. 32). Plaintiff filed two responses to the motion to dismiss (Doc. 34 and 37), asserting that she had provided discovery responses to DOE. The Court denied the DOE’s Motion to Dismiss. (Doc. 38). DOE then filed the instant Motion to Compel (Doc. 40), and Plaintiff filed her Response (Doc. 41). Following an initial pretrial conference held February 25, 2025, the Court fixed a deadline for DOE to file a reply to Plaintiff’s Response that includes a copy of the discovery DOE served on Plaintiff and a copy of Plaintiff’s responses to DOE’s discovery requests. See Order Resulting from Initial Pretrial

Conference Held February 25, 2025 (Doc. 45). DOE timely filed Defendant Department of Education’s Reply in Support of Motion to Compel Plaintiff to Respond to Discovery Requests (“Reply” – Doc. 46). Subsequently, Plaintiff filed Plaintiff’s Request for Defendant to Submit Complete Discovery Responses (“Request” – Doc. 47). Plaintiff’s Request asserts that DOE failed to submit Plaintiff’s November 8, 2024, response to DOE’s discovery requests as part of its Reply, and requests the Court to direct DOE to submit her November 8, 2024, discovery response to complete the record. Plaintiff’s Request represents that the November 8, 2024, discovery response “was received by the Court on November 13, 2024, and acknowledged by Defendant

via email on November 14, 2024.” The only document filed of record in this adversary proceeding on November 13, 2024, is Plaintiff’s Response in Opposition to the Motion to Dismiss (“Opposition” - Doc. 37). The Opposition recites that Plaintiff is “resending the . . . response to the interrogatories, and supplemental information” to the office of the United States Attorney,” mailing to the Bankruptcy Court, and uploading her filing to the Court’s electronic drop box. It is not necessary to require DOE to further supplement its Reply with the discovery responses Plaintiff sent to DOE on November 8, 2024, before ruling on the pending Motion to Compel. The Opposition continues to assert privacy and confidentiality concerns regarding Plaintiff’s health conditions, and contends that DOE is not following the DOE Guidance, as updated. The Opposition also states that Plaintiff “was diagnosed with an autoimmune disorder in 2015 that leads to chronic unpredictable symptoms such as severe fatigue, joint pain, and cognitive difficulties.” Opposition, p. 3.

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Bluebook (online)
Parker v. Dept. of Education/NelNet, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parker-v-dept-of-educationnelnet-nmb-2025.