Pennsylvania Department of Public Welfare v. Davenport

109 L. Ed. 2d 588 · Supreme Court of the United States · 1990

Facts

Edward and Debora Davenport pleaded guilty to welfare fraud and were ordered to pay restitution as a condition of probation. They subsequently filed for Chapter 13 bankruptcy, listing the restitution obligation as an unsecured debt. The Bankruptcy Court held the restitution dischargeable, but the District Court reversed, leading to this appeal.

Issue

Are criminal restitution obligations, imposed as a condition of probation, considered "debts" under 11 U.S.C. § 101(11) and thus dischargeable in a Chapter 13 bankruptcy proceeding?

Holding

Yes. The Supreme Court held that criminal restitution obligations constitute "debts" within the meaning of 11 U.S.C. § 101(11) and are therefore dischargeable under Chapter 13 of the Bankruptcy Code.

Rule

The Bankruptcy Code's definition of "debt" as a "liability on a claim" and "claim" as a "right to payment" is expansive, encompassing all enforceable obligations regardless of purpose or enforcement mechanism. Congress intentionally provided a broader discharge for Chapter 13 debtors by not extending the § 523(a)(7) exception for fines and penalties to Chapter 13 proceedings.

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Case brief last reviewed 2026-01-07. Prepared by CaseReader from the published opinion.