In United States v. Kras (1973) 409 U.S. 434, the Supreme Court upheld a requirement that those seeking bankruptcy protection, including an indigent debtor, must pay a filing fee (which bears a rational basis to having the bankruptcy court system sustained by those who use it). (Id. at pp. 444-448.) "Kras' alleged interest in the elimination of his debt burden, and in obtaining his desired new start in life, although important and so recognized by the enactment of the Bankruptcy Act, does not rise to the same constitutional level" as the marriage interests in Boddie v. Connecticut (1971) (Kras, at p. 445.) "If Kras is not discharged in bankruptcy, his position will not be materially altered in any constitutional sense. Gaining or not gaining a discharge will effect no change with respect to basic necessities." (Ibid.) Not only did the Supreme Court view Kras's economic interest in a bankruptcy discharge as not fundamental, it also concluded the government lacked a monopoly "over the establishment, enforcement, or dissolution of debts." (Ibid.) "In contrast with divorce, bankruptcy is not the only method available to a debtor for the adjustment of his legal relationship with his creditors. The utter exclusiveness of court access and court remedy ... was a potent factor in Boddie. But 'without a prior judicial imprimatur, individuals may freely enter into and rescind commercial contracts ... .'" (Ibid.) "However unrealistic the remedy may be in a particular situation, a debtor, in theory, and often in actuality, may adjust his debts by negotiated agreement with his creditors. ... Government's role with respect to the private commercial relationship is qualitatively and quantitatively different from its role in the establishment, enforcement, and dissolution of marriage." (Id. at pp. 445-446.)