Hardship Discharge vs Voluntary Dismissal

When your plan fails -- which option is better?

Two Options When You Cannot Complete Your Plan

When a Chapter 13 debtor can no longer make plan payments, two primary options exist: request a hardship discharge under Section 1328(b), or voluntarily dismiss the case. The choice between them has significant consequences.

Side-by-Side Comparison

FactorHardship DischargeVoluntary Dismissal
Debts eliminated?Yes (Ch.7-equivalent debts)No -- all debts revive
RequirementsThree-element testGenerally available as of right
Credit reportShows as dischargedShows as dismissed
Discharge bar triggered?Yes (1328(f) applies)No discharge bar
Filing bar triggered?No 109(g) barPossible 109(g) bar
Can refile immediately?Subject to discharge barsYes (subject to 109(g) and stay limits)
Creditor objection?Creditors can objectCreditors can oppose dismissal

When Hardship Discharge Is Better

When Dismissal Is Better

Key difference: Dismissal puts you back where you started -- all debts revive, all liens revive, and creditors can resume collection. A hardship discharge eliminates qualifying debts permanently. If you have significant dischargeable unsecured debt, the hardship discharge is almost always the better option when available.

Third Option: Conversion to Chapter 7

There is also a third option: converting your Chapter 13 case to Chapter 7 under Section 1307(a). This gives you a fresh Chapter 7 discharge without needing to meet the hardship discharge requirements. However, conversion to Chapter 7 means your non-exempt assets could be liquidated, and you must pass the means test. This option is explored in detail at dismissedbankruptcy.org.

Check Your Options

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Related Resources

dismissedbankruptcy.org -- What happens after dismissal and next steps

Requirements -- The three elements of hardship discharge

chapter13plan.org -- Chapter 13 plan modification options

dischargebar.org -- Discharge bar timing after hardship discharge

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Federal Rules Committee

This research supports Suggestion 26-BK-3 to the Advisory Committee on Bankruptcy Rules

Proposing automated Section 1328(f) discharge bar screening in federal bankruptcy courts