Jeneane L. Grimes v. ECMC (In re Grimes), Ch. 13, BK06-81303-TJM, A12-8038-TJM (Oct. 10, 2013)
The debtor established that her age, health conditions and unemployed status were such that repayment of her student loans would be a hardship for her. Her gross income was below the federal poverty level, and her living expenses were meager. It was unlikely her situation would improve sufficiently in the future to permit her to make payments. While her required payments under the lender’s proposed income-based repayment plan may be at or near zero, the interest would continue to accrue for 20 years, resulting in a debt of nearly $100,000 to be discharged when the debtor is 86 years of age. The totality of the circumstances favored immediate discharge of the debt.