September 19, 2018 Being Employed Isn’t Enough to Salvage an Individual’s Chapter 11 Discharge Appeals court talks about discharging a debt when the issue is denial of discharge. 9th Circuit , February 3, 2016 Congress Did Not Abrogate Absolute Priority for Individuals, Five Circuits Now Hold Sloppy drafting in BAPCPA puts individuals at the mercy of dominant creditors in chapter 11. 9th Circuit ,