⚖ Oral Arguments, with Context

The Ninth Circuit considers whether Michael Manion can discharge a debt to Strategic Funding Source, which does business as Kapitus. Manion's company operated mobile bars for Anheuser-Busch and sought financing after that relationship had largely ended, without disclosing the change. The bankruptcy court found a fraudulent omission and held the debt nondischargeable. A bankruptcy discharge normally releases a debtor from qualifying debts. Section 523 keeps debts obtained by fraud from being discharged, but written statements about financial condition are governed by a separate rule. Manion says the lower courts used the wrong rule and the wrong standard for omissions. Kapitus says binding precedent and the trial findings support the judgment.

Manion v. Strategic Funding Source, Inc. (No. 25-2507) — U.S. Court of Appeals for the Ninth Circuit, argued August 11, 2026.