In Cohen v. de la Cruz, 523 U.S. 213 , 217 (1998), the Court decided that a treble damages award that was imposed as punishment for a state-court defendant's fraudulent conduct was nondischargeable under the fraud exception to dischargeability, rejecting the debtor's argument that only an amount equal to the actual value obtained by fraud should be nondischargeable. Cohen, 523 U.S. at 219. In support of its decision, the Court cited "the historical pedigree of the fraud exception, and the general policy underlying the exceptions to discharge." Id. at 223. The Court held that 11 U.S.C. 523(a)(2)(A) prevents debtors from discharging statutory and punitive fraud damages. The Court rejected a fraud perpetrator's contention that he could discharge any liability above the amount he received. See id. at 222. It held that "once it is established that specific money or property has been obtained by fraud . . . 'any debt' arising therefrom is excepted from discharge." Id. at 218-19. It relied on a "straightforward reading" of the statute and on legislative intent to make fraud victims whole. See id. at 217-220. Cohen indicates that whether the debt arises from fraud is the only consideration material to nondischargeability. It also indicates that the Court should not read requirements like receipt of benefits into 523(a)(2)(A) and that the discharge exceptions protect fraud victims rather than debtors.