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Joint Apprenticeship Comm. of United Ass'n Local Union No 307 v. Rezendes (In Re Rezendes)

INNBFebruary 5, 2004No. 18-32196Cited 1 time
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Case Details

Judge(s)
J. Philip Klingeberger
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
bench trial

Related Laws

No specific laws identified for this ruling.

Claim Types

Breach of Contract

Outcome

The court determined that the apprenticeship training obligation owed by Rezendes to JATC is excepted from discharge in bankruptcy under 11 U.S.C. § 523(a)(8), and rejected Rezendes' contractual defenses and undue hardship claims.

What This Ruling Means

**Apprentice Can't Escape Training Debt Through Bankruptcy** This case involved a plumbing apprentice named Rezendes who owed money to a union apprenticeship program. Rezendes had participated in training through the Joint Apprenticeship Committee of United Association Local Union No. 307, which provides education for plumbers. When apprentices receive this training, they typically agree to work in the field for a certain period or repay the training costs. Rezendes owed $6,254.60 to the program and tried to eliminate this debt by filing for bankruptcy. The court ruled against Rezendes, deciding that he could not discharge his apprenticeship training debt through bankruptcy. The judge determined that educational debts like this are protected under federal bankruptcy law, similar to student loans. The court rejected Rezendes' arguments that his contract was invalid and that repaying the debt would cause undue hardship. **What This Means for Workers:** If you enter an apprenticeship program that requires you to repay training costs under certain circumstances, you generally cannot escape that obligation through bankruptcy. Workers should carefully read and understand any repayment agreements before starting apprenticeship programs, as these debts are likely to follow you even through financial difficulties.

This summary was generated to explain the ruling in plain English and is not legal advice.

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