Case Summary:
The District Court remanded this case to apply the appropriate standard for “maliciousness” under Code section 523(a)(6). This Court decided that Defendants' actions weren't malicious because there was no evidence that they consciously disregarded their duty, or that their actions lacked just cause or excuse. Since this Court had initially made an oral ruling, the decision began by itemizing specific findings of fact from trial. This Court then determined that the nature of the duty to be examined was relevant because, even though this Court already found Defendants' actions to be willful, the facts initially determined at trial would not have necessarily been sufficient to find that an intentional tort had occurred. Next, Defendants' actions weren't malicious because there was no evidence that they consciously disregarded their duty of care. The record showed that alleged mechanical issues with their boat were infrequent, and that the issue that occurred on the day Plaintiff was injured was new and unpredictable. Thus, their assumption that the boat would operate as normal was reasonable. Defendant was also attempting to align his conduct with his duty by moving the boat away from Plaintiff when the accident occurred. Plaintiffs also failed to establish a clear ordinary standard of care that Defendants allegedly violated. Finally, the record showed that Defendants acted with just cause and excuse because they were attempting to move the boat away from Plaintiff in an effort to prevent harm.

Statute Reference:
11 U.S.C. § 523(a)(6) -- Nondischargeability - willful and malicious injury

Key Terms:
Duty
Nondischargeability
Remand
Willful and Malicious Injury