What are some of the debts of a debtor who has been discharged from bankruptcy?

Excluding these debts from discharge will not further the bankruptcy goal of a fresh start unburdened by old debts. Wright v. Union Central Life Ins. Co., 304 U.S. 502, 58 S.Ct. 1025, 82 L.Ed. 1490 (1938). Nor will it protect spouses, former spouses and children from being injured by a debtor's discharge.

Exceptions to discharge must be plainly expressed, Gleason v. Thaw, 236 U.S. 558, 35 S.Ct. 287, 59 L.Ed. 717 (1915) and are strictly construed in favor of the debtor, In re Houtman, 568 F.2d 651 (9th Cir.1978).