Law360, New York ( December 4, 2015, 10:04 AM EST) -- In November, the U.S. Supreme Court agreed to review the Fifth Circuit's decision in Husky International Electronics Inc. v. Ritz,[1] to resolve a circuit split regarding the "actual fraud" exception to a debtor's discharge. In Ritz, the Fifth Circuit interpreted the "actual fraud" exception to a debtor's discharge under Section 532(a)(2)(A) of the Bankruptcy Code to require a creditor to prove that the debtor made a false representation.[2] The Ritz decision differed from the reasoning of the Seventh Circuit, which held in McClellan v. Cantrell that no representation is required for the actual fraud exception to apply.[3] The First Circuit, in Sauer Inc. v. Lawson, also followed the Seventh Circuit's reasoning.[4]...