Proponents of relief for student loan borrowers in bankruptcy had reason to cheer this month in both Washington and Oregon. Student loan obligations are presumptively non-dischargeable in bankruptcy absent a showing of “undue hardship.” 11 U.S.C. § 523(a)(8). To determine if a debtor has shown undue hardship, courts follow the three-part test from Brunner. See In re Pena, 155 F.3d at 1111–12. Under Brunner, the debtor must prove that: (1) he cannot maintain, based on current income and
expenses, a “minimal” standard of living for himself and his dependents if required to repay the loans; (2) additional cir