In Grogan v. Garner (1991) 498 U.S. 279, the court addressed the standard of proof with respect to an allegation of fraud, in the nondischargeability context. The court held "that the standard of proof for the dischargeability exceptions in 11 U.S.C. 523(a) is the ordinary preponderance-of-the-evidence standard." (Id. at p. 291.) In reaching this conclusion, the Grogan court took into consideration "the 'fresh start' policy of the Bankruptcy Code." (Grogan v. Garner, supra, 498 U.S. at p. 286.) It stated: "This Court has certainly acknowledged that a central purpose of the Code is to provide a procedure by which certain insolvent debtors can reorder their affairs, make peace with their creditors, and enjoy 'a new opportunity in life with their creditors, and enjoy 'a new opportunity in life with a clear field for future effort, unhampered by the pressure and discouragement of preexisting debt.' But in the same breath that we have invoked this 'fresh start' policy, we have been careful to explain that the Act limits the opportunity for a completely unencumbered new beginning to the 'honest but unfortunate debtor.' The statutory provisions governing nondischargeability reflect a congressional decision to exclude from the general policy of discharge certain categories of debts - such as child support, alimony, and certain unpaid educational loans and taxes, as well as liabilities for fraud. Congress evidently concluded that the creditors' interest in recovering full payment of debts in these categories outweighed the debtors' interest in a complete fresh start." (Id. at pp. 286-287.)