In re Tsurukawa, 258 B.R. 192 (9th Cir. B.A.P. 2001)
    “...[W]e hold that a marital union alone, without a finding of a partnership or other agency relationship between spouses, cannot serve as a basis for imputing fraud from one spouse to the other.”

In re Cox, 41 F.3d 1294 (9th Cir.  1994)
    Discharge granted to wife who was wholly uninvolved and unaware of husband’s bad record keeping

In re Arm, 87 F.3d 1046 (9th Cir. 1996)
    § 523(a)(2)
    Indirect benefit from fraud in which debtor participates is sufficient to find debt is nondischargeable.

In re Lauricella, 105 B.R. 536 (9th Cir.  B.A.P. 1989)
    Insufficient evidence to connect debtor with check kiting scheme of his corp.

In re Figge, 94 B.R. 654 (Bankr. C.D. Cal. 1988), aff’d, 928 F.2d 1136 (9th Cir. 1991)
    Wife not liable for husband’s participation in fraud.

In re Lansford, 822 F.2d 902, 904 (9th Cir.  1987)
    Liability of wife for husband’s fraud