Discharge Withholding Patterns

817 federal bankruptcy cases where discharge was withheld for administrative or procedural failures despite the underlying case otherwise running to completion. The cleanest signal of how procedural traps catch debtors after substantive eligibility is established.

492

Cert of Personal Financial Mgmt failures (60.2% of all withholdings)

21.05

Wisconsin Eastern withholding rate (per 1,000 cases) — highest

10.11

Ch.11 withholding rate per 1,000 cases (highest of all chapters)

817

Total cases — debtor completed bankruptcy but did not receive discharge

What this measures. Discharge withholding is distinct from discharge denial (§ 727(a)) or revocation (§ 727(d)). The case proceeded normally; the debtor simply failed to file the post-petition financial-management course certificate (Rule 1007(b)(7)) or comply with another procedural prerequisite. The discharge can typically still be obtained by curing the defect — but most never are.

By withholding reason

Reason	Count
Cert of Instructional Course for Personal Financial Mgmt	492
Other reasons	262
Cert of financial mgmt course + DSO	29
Domestic Support Obligation compliance	17
Chapter 13 Cert of Eligibility	4
Cert of Personal Financial Mgmt Course	4
Cert of Financial Mgmt + Local Form 2831	4
Cert of PFM + Ch.13 Cert of Eligibility	3
Local Form 2831	2

By chapter

Chapter	Withheld	Total cases	Rate per 1,000
Ch.11	58	5,737	10.11
Ch.13	425	103,194	4.12
Ch.7	334	104,300	3.20

Top districts (per 1,000 cases, volume >=500)

District	Withheld	Total cases	Rate per 1,000
wiebk	32	1,520	21.05
caebk	11	781	14.08
mabk	19	1,441	13.19
kyebk	10	1,227	8.15
kywbk	5	619	8.08
txsbk	202	30,412	6.64
innbk	10	1,508	6.63
tnwbk	12	2,014	5.96
cacbk	29	5,938	4.88
mowbk	181	42,275	4.28

Download the data (CC BY 4.0):
withholding_by_district.csv withholding_by_chapter.csv withholding_by_reason.csv

Methodology

Source: 220,037 federal bankruptcy cases from PACER (2008-2026). Filtered for the nine "Discharge Withheld" disposition codes. District codes follow PACER court conventions (e.g., wiebk = U.S. Bankruptcy Court, Eastern District of Wisconsin). Rate denominators are total cases in that district/chapter, not just those that reached the discharge phase.

Caveats. The "Other Reasons" bucket (262 cases) is opaque. Some withholdings may eventually be resolved by curing the defect — this dataset captures the disposition recorded at case close. Per-district rates can be skewed by tiny denominators; we set a 500-case minimum for ranked tables.

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