Ross v. Universal Studios Credit Union

In Ross v. Universal Studios Credit Union (2002) 95 Cal.App.4th 537, the underlying case involved a judgment creditor who filed a complaint in the bankruptcy proceedings requesting a determination that its 1994 judgment against Ross, the bankruptcy petitioner, would be declared nondischargeable pursuant to 11 United States Code section 523(d). This underlying case was held not to support a state malicious prosecution action, because of the policies presuming the Bankruptcy Code provides adequate remedies for the resolution of any abuse that may occur in such proceeding and that otherwise, the jurisdiction of the bankruptcy court would be undercut.