Paul L. Caron

Wednesday, June 9, 2010

NY Times: Should Student Loans be Dischargeable in Bankruptcy?

New York Times, Student Debt and a Push for Fairness:

If you run up big credit card bills buying a new home theater system and can’t pay it off after a few years, bankruptcy judges can get rid of the debt. They may even erase loans from a casino.

But if you borrow money to get an education and can’t afford the loan payments after a few years of underemployment, that’s another matter entirely. It’s nearly impossible to get rid of the debt in bankruptcy court, even if it’s a private loan from for-profit lenders like Citibank or the student loan specialist Sallie Mae.

This part of the bankruptcy law is little known outside education circles, but ever since it went into effect in 2005, it’s inspired shock and often rage among young adults who got in over their heads. Today, they find themselves in the same category as people who can’t discharge child support payments or criminal fines.

Now, even Sallie Mae, tired of being a punching bag for consumer advocates and hoping to avoid changes that would hurt its business too severely, has agreed that the law needs alteration. Bills in the Senate and House of Representatives would make the rules for private loans less strict, now that Congress has finished the job of getting banks out of the business of originating federal student loans.

With this latest initiative, however, lawmakers face a question that’s less about banking than it is about social policy or political calculation. At a time when voters are furious at their neighbors for getting themselves into mortgage trouble, do legislators really want to change the bankruptcy laws so that even more people can walk away from their debts?

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Through a series of unfortunate and unexpected events, I now owe more in student loans than I will likely ever be able to pay in a lifetime of earnings (and that assumes I am able to live and work until I am 85).

Short of winning a really big lottery, I will never get out of this because the interest is compounding faster than I am able to pay.

The sad thing is that the original principle really was not that great. The fact is since the lenders know I cannot do much about it, they invent fees and penalities (the contact says they can) which grossly inflate what I owe.

I probably would have encountered some issues paying no matter how the loan was stuctured simply because of the magnitude of financial devastion I encountered and I am OK with reasonable penalities. My main objection is that when you completely protect an entity from any consequences, they tend to abuse the situation. Unlike a business or a person with a credit card debt, I have no leverage in which to negotiate with. There is nothing I can do to improve my situation expect find some way to earn a lot more money.

What you do not realize is that when you are caught in this situation, you do not have the freedom to anything you want to earn more money. Starting a business requires money, but as soon as there is income, you have to pay 15% of the gross income. Not many businesses can survive that - mine sure didn't.

Get a big promotion and think you are going to do better - nope. This is when they threaten take you to court to see if they can get a larger chunk...afterall, you have been surviving just fine on previous earnings. This one I won, but it cost me the extra I would have earned through lawyers fees.

And apparently, I do not qualify for undue hardship. The judge in my case thought that I might be able to earn enough money in my lifetime to pay it off because we were at one point earning enough - never mind the irreversible problems that eliminated those earning.

Discharge will not solve my problems, but it would make suicide a less appealing option.

Posted by: Phil Smoth | Jun 21, 2010 11:18:10 AM

Yup, diploma mills abused student loans, which is how the whole mess got started. But are "legitimate" universities any less guilty than the local truck driver school if they let students run up debt while doing "personalized" majors in religion and woman's studies? At least the truck driver credential may mean you drove a truck occasionally and can get a job.

Universities should be effective co-signers of student loans out of their endowments. Maybe they'd be a bit more careful to let kids major in unemployment studies if they were on the hook for the debt.

Posted by: Foobarista | Jun 10, 2010 4:01:35 PM

So let's talk about one of the girls who works for me in my self-owned, self-employed business. She went to college for SEVEN years for a general studies degree. What did I go to college for? Ohhhh... I never did. I just took the initiative, with hubby, to open another business, while still owning and running the one I've had for 12 years. That doesn't count the third business we closed years ago so hubby could take a better paying job with a corporation instead of working for himself. Hubby has two years of business at a local community college that served him quite well and never left him with a ton of outstanding debt.

Do I think the system needs to be reformed to accommodate certain changes? Yes. Do I think SLD needs to *poof* go away because 50k for a GS or LA degree is just too much for wittw baby who had to go to cowwig at a big scoow? Nope. Not when I see some of the college kids in my college town roll through here, plastered drunk, acting stupid, dressing dumb and not even speaking properly. Look at their FB pages; if there are weekly updated pics of them at the local bar hanging all over an equally drunk member of the opposite sex when they have class the next day, then I have NO sympathy. Most of them only live here to go to the college in town, so to see them like that, knowing that they are only here in the first place under the pretense of getting educated, ticks me off. Just another potential 'entitled class' I'm supposed to pay for. Again.

Posted by: LickyLicky | Jun 10, 2010 11:46:36 AM

Since the Fed is now the lender, if these loans are dischargable in bankruptcy, how long before it becomes solely a political issue, and Congress starts passing laws to keep the fed govt from destroying the credit rating of 100,00's of young people, (many of whom are members of "vulnerable" population groups that need to be "protected"?)

I think the key is the amount of the loans--students should not be able to borrow more than half the cost of tuition with any federal involvement at all. That would keep college costs down and prevent the current "just borrow what you need to and we'll worry about it later" mentality that currently prevails.

Posted by: Joe | Jun 10, 2010 11:29:43 AM

Going forward, student loans should be dischargable, and not guaranteed by the government. That change should absolutely not be retroactive.

Posted by: MattJ | Jun 10, 2010 11:03:57 AM

This will drive up rate of Private Student Loans.

For Gov supplied Student Loans the rates might go up, but mostly the defaults will fall as a loss to Taxpayers.

Posted by: Purpleslog | Jun 10, 2010 10:54:31 AM

I like the point, stated above, that the higher education institution should make the loans, like out of their endowment funds. Nice test of how much they believe in the future value of their "product".

I've helped three of my four kids with their higher education expenses. The fourth went through on the GI bill after five years in the Navy. My daughter was trying to decide between in-state (U. of Colorado) and Syracuse. When I told her we'd help with living expenses either place, but the tuition part was up to her, in-state attendance suddenly became much more attractive.

The cachet of going to an expensive school is way overrated, at least for undergraduate education. It's time for young people of college age to learn that the quality of their education depends mostly upon their own effort, and that a more prestigious school does not necessarily graduate more "educated" people. (My in-state education (in Kansas) was sufficient to repetitively hit the 99th percentile on national exams in the field of medicine.)

Dischargeability of student loans simply prolongs the economic infancy of young adults who should be learning to shop for value--something they seem usually capable of doing when making other purchases.

Posted by: leishman | Jun 10, 2010 10:34:52 AM

I wrote a long, long post, but I'll cut it short. Almost all of my loans were seized by the government. I owe $40,000 extra due to multiple fly-by-night government-contracted loan servicers claiming ownership of the same loans. Other loans have been lost entirely (no, sadly, not $40,000 worth). Many of these companies go months without functioning websites or call centers, while collecting millions in payment from the government. When you do reach them, none of them has any idea what the hell is going on. My original promissory notes and contract terms are not worth a damn thing; the government sends me nice letters explaining their wonderful new authority to do virtually whatever they want.

Deferment terms are useless. How am I supposed to be on unemployment to qualify for an unemployment deferment, when I'm right out of school. No job after more than a year... 90% of my peers have no jobs either, of any kind.

My generation is not going to forget this, nor will we forget the way we're expected to foot the bill for the Social Security implosion. If I had a big red button here that would kill everyone over 35 or so, I'd gleefully mash it like a monkey on speed, and to hell with the collateral damage. Then I'd do a little dance and hit it again just to make sure it worked. This is the world you've made, now you get to have fun living with us in it.

Posted by: not amused | Jun 10, 2010 10:22:39 AM

Who here wants their tax dollars to finance worthless degrees? Also, who wants to finance someone's $25,000/year degree when there are plenty of quality colleges, universities, and community colleges that can provide a degree for substantially less? When you take the federal government out of providing student AND home loans, people and the lending institutions themselves will be much more wary about tossing good money after bad risks.

Posted by: GW | Jun 10, 2010 10:18:51 AM

I am not a bankruptcy lawyer, but I believe student loans have not been dischargeable for a long time, going back way before 2005.

Posted by: Daniel | Jun 10, 2010 9:40:54 AM

I think most student loans should be non-dischargeable.

However, I think they should only be available to degree programs that show positive Net Present Value (NPV).

This will include some vocational programs and some professional programs, but will probably exclude many liberal arts programs.

The monthly payment should be capped to a fraction of your income - this will encourage banks not to extend credit to a point where the payment exceeds the cap.

WilliamMartel beat me to a few of these and makes some other good points.

But I am starting to think the entire bankruptcy and lending apparatus(particularly unsecured, like credit cards and student loans) could use a comprehensive reform.

Posted by: J | Jun 10, 2010 9:37:10 AM

What is the estimated total of outstanding student loans?

Posted by: BBC | Jun 10, 2010 9:35:33 AM

If the loans are non-dischargeable, then IMO the only entity that should be issuing them should be the educational institution. The expected result would be the education provider encouraging students to earn degrees that would generate income sufficient to repay the loan.

If the loans are dischargeable, it should be after a reasonable delay, say 10 years, and they should not be guaranteed by the government. I would also explicitly allow lenders to set interest rates and loan limits based in part on the degree being earned.

Either approach would be an improvement over what we have now, which is basically a situation where both students *and* lenders are taking advantage of the taxpayer via the federal government.

Posted by: rosignol | Jun 10, 2010 9:30:53 AM

In a word, no. As a taxpayer i am stuck with being the guarantor of the loan without any input as to whether approve or disapprove of the loan. What is needed is reform as others above have posted to be able to refinance higher interest loans to a lower rate when interest rates are low and on the up front side of the loan origination limit those loans to studies in areas that have a reasonable probability of generating sufficient income to be able to pay back the loans.

Posted by: cubanbob | Jun 10, 2010 9:21:35 AM

Of course student loans should be fully discharged in bankrupcy proceedings.

Forgiveness of loans should be a taxable event only to the original principle amount of the loan (if that). Loan amounts arising from compounded interest should simply be wiped off the books without taxable consequence.

The present system amounts to a lifetime indenture that cripples most prospects for future professional employment. It cannot continue - and it won't. Most student loans now in default will simply never be repaid in full.

The question now is how to unwind the mess with the least collateral damage.

The central problem is that there is zero return on investment for large sectors of the Education and Training industry. It does not really make good business sense for any institution to loan $150,000 to a student to fund typical degree from a liberal arts college. With or without that degree, the student will be likely be working the same low-paying entry-level job at age 24.

Trade schools are not any better. Outside of law, engineering, and medicine, the only reliable way to determine whether a program of education or training has value is when an employer is willing to pay for it.

The present system exists only because of ill-advised government sanctions that permit lenders to bleed their unwary victims for the rest of their lives.

Posted by: Michael | Jun 10, 2010 9:20:42 AM

My opinion: These are the future Civilian Service Corps. How simple: discharge your student loan with two years' service in the new Corps. Perfect, a ready-to-mold source of young cadre, fresh from the public school system.

Posted by: Norm | Jun 10, 2010 9:10:49 AM

No, they should not be dischargeable so long as they are being backed by the federal government.

The higher education bubble of extraordinary tuition rises is based on cheap credit. With discharge in bankruptcy, the government can just print more money to cover the amounts lost through bankrultcy filing, passing the loss onto the public at large, and keeping the Higher Ed Bubble afloat.

The only true solution is to get the government out of the student loan business. Then you could make the loans dischargeable, and the banks would take far more care in who they loaned to. No free lunch on the public's wallet, no more tuition inflation.

Posted by: Jeremy Abrams | Jun 10, 2010 9:03:21 AM

How about converting student loan debt into a sort of income tax, so that you cannot be required to pay more than 15% of your annual income over $40,000. If you can't earn $40,000 a year with your expensive degree, the lender eats the loss with no government bailout. Money for worthless majors like Woman's Studies would dry up real fast under this system.

Posted by: Dave | Jun 10, 2010 8:44:38 AM

Here's the trade-off:

If we make student loans dischargeable by bankruptcy, this by default makes every last student loan a higher risk. Would there be any structure in place to assure that said risk would be appropriately compensated--say, via higher interest rates, government backing/subsidies, etc.?

Bluntly put, if we make student loans dischargeable, the nation--either taxpayers or other loan seekers--would end up paying the additional costs of those defaults, and make no mistake about it, there WOULD be such defaults. LOTS of them. I'm sorry, but this exercise would simply gives others the opportunity to escape personal responsibility at our collective expense. I cannot condone it.

Posted by: Alexander D. Mitchell IV | Jun 10, 2010 8:42:14 AM

They ought to be dischargeable, perhaps with time or projected income restrictions like those mentioned in comments above to prevent abuses. However, the educational institution should to be treated as a co-signer of the loan and be forced to repay any defaulted amount. After all, the school has more information on the value of the education they are providing and ought not encourage students to take out loans that will ruin their lives.

Posted by: Kevin | Jun 10, 2010 8:42:05 AM

The loans should only be dischargeable if the government gets out of the business of making/guarantying those loans. As long as the government is involved, lots of bad loans will be made. Since the government won't evaluate the "investment" being made, people will be encouraged to borrow to major in worthless social majors that have no market because the degree has no value.

If all the loans are made by private entities with no government back up - sure go ahead and make them dischargeable in bankruptcy. The private lenders will, by and large, avoid loaning against a social degree or to someone who looks like a credit risk because their highschool grades were poor. (I know, some bad loans will be made, but a lot fewer than if the government is just showering money on every psych or women's study major.)

Some people should not go to college. If someone really wants to go, despite private lenders refusing a loan, they can join the army and qualify for the GI bill benefits. Or, here's a crazy idea, work for a few years and earn the money.

Posted by: Over50 | Jun 10, 2010 8:31:12 AM

Of course student loans should be dischargeable, but we also need to stop the government from loaning or guaranteeing student loans this is not the correct use of tax dollars.

Posted by: Rickster | Jun 10, 2010 8:17:52 AM

I have 1 in College and 3 to go.... The Costs are insane..
Colleges can get away with charging these outrageous fees partially because of the easy accessibility to STUDENT LOANS...It is fairly easy to borrow (and go ito debt) for very large amounts of money...I get it.. I know the problem...
However, I am also a Bond Holder of NJ Student Loan Municipal Bonds used to make these loans..I have lent my hard earned money to NJ to make loans to kids to go to college and make a better life for themselves and for our society in general.
That is aat "least" a moral contract with those who borrow..with those who are willing to lend...
For them to declare bankrutpcy and walk away...That is a violation of the good faith between "borrowers" and "lenders"...
This is a slippery slope indeed.. Bad precedent was set by trashing the secured Bondholders of Chrysler, and granting equity to the unions. I think the entire country needs a serious lesson on the Rule of LAW and what a contract means.
Apologies for the long and winded post..

Posted by: BobSledd | Jun 10, 2010 8:17:49 AM

Good points, everyone. You are all missing a critical point, unless I missed something. I am in the category of middle class with assets. My 2 children, now 21 and 22 entered college, the "American Dream", at the same time my business dropped 50% and my assets dropped 75%. We have had to take out Citibank loans for, at this point, $250,000 combined. My credit and home are at risk. I know my kids can't pay this back. They don't qualify for "aid", other than loans, because their parents, I, "make too much". When they graduate, if they can't pay, I have to. Being self employed, I will not be able to retire because my self-funded pension is almost $0. (side note: the public sector employee who retires at 52 on $50k/year is equivalent to my self-funded savings of $1.5 million savings). This predatory college system picks and chooses who gets grants, goes for free or reduced, who gets into public colleges bases on demographics (income, race, different entry standards, etc.). The colleges and universities are fueled by the gov't - banking industry incestuous relationship that guarantees money, therefore tuition increases far beyond inflation, to the schools, while forcing families into financial bondage.

Posted by: JPSerino | Jun 10, 2010 8:17:12 AM

@ WilliamMartel:
I would tend to agree with your assessment, within reason. I went to a fully accredited online program, mixed student loans and GI Bill, finished my degree while working full time, and am gainfully employed in my field.

One thing I would add, if you are going to restrict what schools that you give loans for, you are also going to have to restrict the majors that you will loan for. For example, degrees in "whatever studies", Liberal Arts, journalism, or any of the other soft arts that produce nothing but unskilled workers with a useless degree.


Posted by: Pol Mordreth | Jun 10, 2010 8:02:30 AM

As someone who does not practice bankruptcy law, this issue was always one of abstract social and economic policy until very recently when one of my businesses encountered severe financial trouble. If my attempts to save my business fail I am faced with the prospect of being forced to file for bankruptcy. Unfortunately, the shame of not meeting my obligations and the damage to my creditworthiness will be compounded by the fact that I will still be over one hundred thousand dollars in debt because of student loans. Thus, I will have lost everything, sought protection under the statute as a good faith debtor and still be burdened with an insurmountable debt.

I do not relish the prospect of bankruptcy. I do not relish the prospect of defaulting on my obligations and leaving my creditors with a loss. I do not relish the prospect of unscrupulous students filing for bankruptcy the day they receive their diploma. I value my word and the moral obligation implicit in these contracts. But what is the use of the Bankruptcy Code if I am still in debt when driven to this last extreme?

Posted by: Anon | Jun 10, 2010 7:42:36 AM

There is a substantial difference between student loan debt and other types of debt. SLD was acquired to obtain something that should be of value for the rest of the borrower's life. What good is a DVD player, a closet full of clothes, or for that matter a car after 10 years? Unless he studied art history, his education should turn out to be a good investment for years to come. To allow him to shuck that obligation before it begins to show returns merely shifts the cost of his education to others who will not benefit from it.

The real issue here is not SLD but intstead the cost of higher education itself. Because of the ease of obtaining a SL (due in large part because they are not dischargeable in bankruptcy) the hurdle of paying for an education is no longer such a big hurdle. The money is there, removing the 'can I afford it?' question from the equation. If there were no student loans, college would still be there and the cost of education would drop dramatically.

Posted by: Redman | Jun 10, 2010 7:40:27 AM

Yes, student loans should be dischargable in bankruptcy. These "loans" are actually a form of three-card monty. If a borrower misses a payment or is late in paying--presumably because he has lost his job or some other contingency has arisen-- confiscatory late fees and penalties are assessed. Add to this the miracle of compound interest, and soon the student's debt has increased from $20,000 to $100,000 plus. The student continues to pay the minimum payment for life, or maybe for eternity, and can never catch up.

Posted by: miriam | Jun 10, 2010 7:29:30 AM

I've practiced bankruptcy law for a long time, and I believe student loans should be dischargeable, or at a minimum, dischargeable in chapter 13.
Student loans got their nondischargable status in the 1970s after complaints (including a "60 Minutes" piece) about med students financing their educations with student loans and taking bankruptcy prior to going out in practice to make six-figure incomes. In those days the bankruptcy laws did not contain the "means test" the "projected disposable income" test or the "substantial abuse" provisions which now exist in the Bankruptcy Code. I don't believe the abuses described in the "60 Minutes" piece would take place today under current law if student loans were dischargeable.
The argument gets made that student loans are somehow special because the lender doesn't get collateral but has to count on the student's future earning capacity. Of course the same can be said about most other unsecured debt that routinely gets discharged. Besides, making these loans dischargeable might cause lenders to think twice before giving a loan to some student who wants to get a four-year degreee in naval-gazing or some other useless PC course of learning.
I've seen student loan debtors who, thanks to economic downturns, bad choices of majors, and (mainly) compounding interest, have absolutely no chance of repaying the loans and basically have no reason to try to make anything of themselves. The loans are basically uncollectible.
There are some debts which should be non-dischargeable, such as child support, claims arising from criminal or fraudulent conduct, taxes, or drunk driving. Student loans, in my view, do not belong in the same category.
It would be better to allow student loan debtors to discharge those debts to get a fresh start and be able to resume productive taxpaying lives. Or, at least as a compromise, allow them the discharge upon completing a Chapter 13 plan where they submit all projected disposable income to creditors for a five-year period.

Posted by: bdonovan | Jun 10, 2010 7:20:25 AM

And of course this kind of loan forgiveness must be taxable, because Uncle Sugar can't miss any of that income....

Posted by: Georg Felis | Jun 10, 2010 7:06:26 AM

Wouldn't making student loans dischargeable in bankruptcy drive down costs of schooling? I may be wrong but this would cause lending to drop and then without the lending available schools couldn't have an expectation to have such a high cost and have students meet the price without any aid.

Posted by: Matthew | Jun 10, 2010 6:53:41 AM

The problem is most students getting loans are insolvent to begin with. What's to stop everyone from getting big loans to get their degrees and then just walking away, starting off with a free education?

Posted by: Mark | Jun 10, 2010 6:44:23 AM

In a word, yes.

Posted by: Mick Andrus | Jun 10, 2010 6:43:45 AM

Yes, student loans should be dischargeable via bankruptcy, but a mechanism should be in place preventing dischargabilty immediately after graduation, i.e 5 to 10 year buffer.

In the aternative, allow student loans to be modified, i.e. up to 100% of the student loan can be forgiven but the borrower incurrs a tax liability for the amount forgiven. If a borrower owes $50,000 in student loan debt and the guarantor forgives the entire $50,000 the borrower incurrs a tax liability on the $50,000 amount based on the borrower's tax bracket. This would give the borrower relief, but not let them escape total reponsibility for the student loan.

A third alternative would be a mixture of bankruptcy and debt forgiveness. The current student loan system is, in my opinion, unAmerican in our free market, capitalist economy.

Posted by: R. Ferrar | Jun 9, 2010 1:00:01 PM

The program, the way it is currently set up, is predatory. Bankruptcy or other options need to be introduced. Some suggested reform examples:

1) Allow bankruptcy, not immediately, but 7 to 10 years after the borrower has finished school. This would prevent borrowers from using bankruptcy immediately after finishing school to dump their loans.

2) Allow the interest rate on borrower's loans to float, not be fixed. Currently borrowers can only consolidate loans once and whatever the interest rate at the time of consolidation is the one they are stuck with throughout the life of the loan. So if they consolidated at 8.5% interest and market rates are now 4.0% they cannot take advantage of the 4.0% rate.

3) Curtail the type of "education" borrowers can use student loans for. Currently almost any type of school can be used for student loans, i.e. secretarial, so called art institutes, cosmetology, on line colleges etc.... Since student loans are non-dischargeable this opens the door to a) abusive charges by the "education providers" some cosmetology programs charge more than college or universities, b) almost any organization can claim to be an education provider and therefore eligible for their enrollees to use/abuse student loans and c) bring student loans back to their original intent student loans for colleges not programs where the degrees or certificates are not worth the paper they are printed on.

4) Student loan lenders are encouraged to have borrowers default. If borrowers default they can take up to 22.5% of the loan as a collection fee then pass the full amount to the guarantor. Ex.: Student "X" has $100,000 in student loans he defaults. The lenders can tack on $ 22,500 for collection actions, without any work on their part, then pass the enitre $122,500 to the guarantor, making an easy $22,500 on top of the $100,00.

5) Bankruptcy was meant to eliminate debtors' prisons, yet not allowing student loans creates a debtors' prison.

Here's my take on the student loan industry as it is currently set-up:

Student Loans- The Modern Day Scarlet Letter

I did what everyone says to do in order to have an opportunity at success and a “good” life, but all it has brought me is pain and misery. Get an education they say, I did that. This will enable you to succeed, they say. Not in my case. All I have to show for my “education” are layoffs, unemployment and empty promises.

Student loans are to help you achieve, I did that. But when life does not go as planned or your dreams are dashed, such assistance to attain those dreams imprisons one to poverty, despair and indentured servitude. Black balled due to bad credit relating to Student Loans one can’t find gainful employment to pay back the loans. Yet like a loan shark or racketeer the “loans” keep growing exponentially while at the same time preventing one from getting back on the track of life, productivity and employment, i.e. living. One becomes jailed in a debtor’s prison that was supposed to not exist in the US. Harassed and threatened by student loan sharks and racketeers, who would be put in jail if they weren’t given sanctuary by the government, life’s purpose slips away, my education empty promises and dreams unfulfilled. Yes, they are a government approved criminal organization preying on those in pursuit of the illusionary American dream; while at the same time enriching the “mob bosses” at the top of the student loan pyramid and discarding the rest of us like yesterday’s newspaper.

A theology of human belief extorting one to get their “pot of gold” and be damned those destroyed on this path. The true human soul, one of: self-importance, self-service, self-righteousness and callous indifference to others. A caste system where money is all that matters whether it is achieved by immoral means and regardless of the victims’ corpses left in one’s wake.

No I am not delusional, depressed or any other medical mental mirage. We all have pain and set backs. We are taught to get up wipe the dirt off and continue the fight. But if the deck is stacked against you and the only one’s being enriched by your labor are the student loan sharks and racketeers, it isn’t worth it. They want to keep you an indentured servant or in debtor’s prison; a prison preventing you from achieving some semblance of dignity, of purpose. Why should they care? When their mistakes catch up with them they can go receive a government handout, which enables them to continue to indenture students and keep you in debtor’s prison, even as they stand on your corpse.

Posted by: WilliamMartel | Jun 9, 2010 12:42:37 PM