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In re Csigi — 9th Cir. BAP (argued September 10, 2026)

No. 25-1058 Argued September 10, 2026 Published September 13, 2026

The Ninth Circuit Bankruptcy Appellate Panel considers whether Steven Csigi can discharge about $564,000 in bankruptcy. His wife, Marylin, was trustee of her mother’s trust. A bankruptcy court found she misappropriated $858,639, including money used to settle a lawsuit against Steven and his family, expand their home, buy a car titled to Steven, and fund his bank account. After Steven filed Chapter 13, successor trustee Villia Ponce sued. The court held those benefits unjustly enriched Steven and bankruptcy could not wipe out the debt. It treated the debt as one for Marylin’s fiduciary defalcation—a culpable breach of fiduciary duty—even though Steven was not the trustee. Steven says the Supreme Court’s Bartenwerfer decision cannot make a passive recipient’s debt nondischargeable without an agency, partnership, or similar relationship. Ponce says the Code looks to the debt’s source and character, which she says flowed directly from Marylin’s misconduct.

In re Csigi (No. 25-1058) — United States Bankruptcy Appellate Panel of the Ninth Circuit, argued September 10, 2026.

Sources
Argument audio — U.S. Court of Appeals for the Ninth Circuit (public domain, 17 U.S.C. § 105):https://cdn.ca9.uscourts.gov/datastore/media/2026/09/10/25-1058.mp3
Argument page — U.S. Court of Appeals for the Ninth Circuit:https://www.ca9.uscourts.gov/cases/streams-videos/archive?case=25-1058&hearingDate=2026-09-10
Argument calendar — Ninth Circuit Bankruptcy Appellate Panel:https://cdn.ca9.uscourts.gov/datastore/uploads/bap/hearings/2026/09/2026%2009%2010%20HNL-1.pdf
Partial-summary-judgment decision — U.S. Bankruptcy Court for the District of Hawaii via GovInfo:https://www.govinfo.gov/content/pkg/USCOURTS-hib-1_23-ap-90019/pdf/USCOURTS-hib-1_23-ap-90019-0.pdf
Earlier related appeal — Ninth Circuit Bankruptcy Appellate Panel:https://cdn.ca9.uscourts.gov/datastore/bap/2024/07/26/23-1009.pdf
Earlier related appeal — U.S. Court of Appeals for the Ninth Circuit:https://cdn.ca9.uscourts.gov/datastore/memoranda/2025/10/09/24-5518.pdf
Earlier trial decision — U.S. Bankruptcy Court for the District of Hawaii via GovInfo:https://www.govinfo.gov/content/pkg/USCOURTS-hib-1_21-ap-90012/pdf/USCOURTS-hib-1_21-ap-90012-0.pdf
Bartenwerfer v. Buckley — Supreme Court of the United States:https://www.supremecourt.gov/opinions/22pdf/21-908_n6io.pdf

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