Robin Miller of CBAR reports:
A debtor who alleges a violation of § 524(a)(2) must establish by clear and convincing evidence that the creditor (1) violated the discharge injunction and (2) did so with actual knowledge of the injunction. The standard does not require proof that the creditor deliberately violated the injunction.
In re Campbell, 2014 WL 32161 (Bankr. E.D. Ky., Jan. 6, 2014)