As reported by Robin Miller of CBAR, a Michigan Debt for statutory conversion was nondischargeable under Code § 523(a)(6):
Based in part on facts established in the state court judgment, and in part on facts established in the trial of the creditor’s adversary proceeding, the court found that the debtor’s injury to the creditor was also “willful,” thereby establishing the remaining element of § 523(a)(6). The creditor paid the debtor $50,600 (of the total contract price of $59,000) to purchase a Chrysler 300 automobile and convert it to a limousine, and the debtor thereafter retained both the vehicle and the creditor’s $50,600.
Treble damages and attorney’s fees awarded in state-court judgment for conversion were all nondischargeable under Code § 523(a)(6):
The debtor’s judgment debt to the creditor for conversion included treble damages and a specific amount for attorney fees, based on the Michigan conversion statute. Under the Supreme Court’s decision in Cohen v. de la Cruz, 523 U.S. 213, 118 S.Ct. 1212, 140 L.Ed.2d 341 (1998), the entire judgment amount was nondischargeable under § 523(a)(6), as the holding and reasoning of Cohenapplies to actions under § 523(a)(6).
In re Pixley, 504 B.R. 852 (Bankr. E.D. Mich., Jan. 24, 2014)
(case no. 2:10-bk-62556; adv. proc. no. 2:10-ap-6665) (Bankruptcy Judge Thomas J. Tucker)