Husky International Electronics, Inc., Petitioner v. Daniel Lee Ritz, Jr. — Thomas, J., Dissenting

Summary

Justice Thomas dissents, holding that the Bankruptcy Code’s §523(a)(2)(A) exemption for "actual fraud" does not extend to debts arising from fraudulent transfer schemes because the statute requires a false representation that induces the creditor and the phrase "obtained by" implies causation at the inception of the debt. He argues that Congress did not intend to cover such schemes under this provision.