What is the test for "malicious injury" in bankruptcy law?

The "malicious" injury requirement is separate from the "willful" requirement. In re Su, 290 F.3d at 1146. An injury is "malicious" if it involves "(1) a wrongful act, (2) done intentionally, (3) which necessarily caused injury, and (4) is done without just cause or excuse." In re Jercich, 238 F.3d at 1209, citing, Murray v. Bammer (In re Bammer), 131 F.3d 788, 791 (9th Cir. 1997). This definition "does not require a showing of biblical malice, i.e. personal hatred, spite, or ill-will." In re Bammer, 131 F.3d at 791.

"Bankruptcy courts recognize and apply the basic principles of res judicata in determining the effect to be given in bankruptcy proceedings to judgments rendered in other forums." Comer v. Comer (In re Comer), 723 F.2d

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