ORDER GRANTING PLAINTIFFS MOTION FOR DEFAULT JUDGMENT Robert Walsh, Jr., sued the U.S. Department of Education, seeking a determination that his federal student loan debt, as described in his complaint (and on his bankruptcy forms), would not be excepted from the discharge that he has since been granted under 11 U.S.C. § 727(a). After the court clerk entered a default against the Department [Dkt. No. 8], Mr. Walsh applied to the Court for a default judgment [Dkt. No. 12]. See Fed. R. Civ. P. 55(a), (b)(2); see also Fed. R. Bankr. P. 7055. He also later filed a supplemental affidavit to support his request [Dkt. No. 19]. The Department has not participated in this adversary proceeding. Overall, through satisfactory evidence, Mr. Walsh has established that he is entitled to the relief sought in his complaint. See Fed. R. Civ. P. 55(d). His complaint contains well-pleaded factual allegations, accompanied by a partially completed attestation form. And his supplemental affidavit provides additional disclosures and documentation. None of this has been contested. Taken together, the evidence shows that excepting the student loan debt from
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discharge would impose an undue hardship on Mr. Walsh.1See 11 U.S.C. § 523(a)(8). That conclusion can be reached under any formulation of the standard for dischargeability of student loans in bankruptcywhether the Brunner test, the totality-of-the-circumstances test, or any other reasonably conceivable test.
Thus, given the above circumstances, Mr. Walshs application for a default judgment is granted. The Court will enter such a judgment accordingly.
Dated: June 17, 2026
Michael A. Fagone
United States Bankruptcy Judge
District of Maine