The United States Supreme Court Declines the Chance to Establish a Uniform Approach for Determining

The Unites States Supreme Court denied a debtor's petition for a writ of certiorari in Tetzlaff v. Educational Credit Management Corporation, No.15-485 (cert. denied Jan. 11, 2016). By denying the petition the Supreme Court declined the chance to create a uniform approach for determining whether or not the repayment of a student loan constitutes an undue hardship on a debtor. There currently is a split in the circuits with the majority of the courts favoring the Brunner test which is more demanding, while the minority of the courts looking at the totality of the circumstances.