In re Dollaga, 260 B.R. 493 (9th Cir. B.A.P. 2001)
          A person (in this case, the debtor’s divorce lawyer)who is not a spouse, former spouse, or dependent of a debtor may not sue for nondischargeability under §523(a)(15).

Renfrow v. Draper, 232 F.3d 688 (9th Cir. 2000)
          “...[I]f a divorce decree provides for the payment of attorney's fees, and state law issues are litigated in the bankruptcy proceedings, attorney's fees are available, but only to the extent that they were incurred litigating the state law issues....Ms. Renfrow is entitled to recover the attorney's fees she has incurred in litigating the validity and the amount of Mr. Draper's debts in the bankruptcy proceeding.” She's also entitled to the attorney's fees she incurred in the state court proceedings before the bankruptcy was filed, and to reasonable costs in both the bankruptcy and state court action.

In re Myrvang, 232 F.3d 1116 (9th Cir. 2000)
          In re Jodoin properly allocates the burden of proof under § 523(a)(15). The bankruptcy court has the discretion to discharge a portion of the debt in question. In re Taylor, 223 B.R. 747 (9th Cir. B.A.P. 1998) disapproved. But the imposition of a penalty provision if the debtor missed a payment was beyond the authority of the bankruptcy court.

In re Short, 232 F.3d 1018 (9th Cir. 2000)
          1) Debt that was specifically incorporated into a decree of dissolution was “incurred in the course of a divorce or separation.” 2) bankruptcy court properly took into account a live-in girl friend's income in determining whether the debtor had the ability to repay the debt.

In re Jodoin, 209 B.R. 132 (9th Cir. B.A.P. 1997)
          Burden of proof between debtor and creditor - once plaintiff demonstrates that the debtor incurred the debt in connection with divorce, the burden shifts to the debtor to prove subsections (a) and (b). The word “unless” just prior to the subsection is crucial to this finding. It creates an exception within an exception