Case Summary:
Creditors filed adversary proceeding under 11 U.S.C. § 523(a)(2)(A).  The debtor had been treated by the creditors for injuries she had suffered.  The debtor executed a “Financial Responsibility Form” under which she agreed to repay the creditors from any personal injury settlement she received.  Although she did ultimately receive a settlement, she did not pay the creditors.  The creditors contended that her actions constituted fraud under § 523(a)(2)(A).  They also asserted a hospital lien.  The court found that the documents in question did not rise to a lien, equitable or otherwise.  Further, there was no evidence that the debtor executed the Financial Responsibility Form with an intent to deceive.  Adversary proceeding dismissed.

Statue/Rule References:
11 U.S.C. § 523(a)(2)(A) -- Nondischargeability - Fraud

Key Terms:
Fraud
Security Interests - Creation