This article analyzes a controversial bankruptcy decision, Sanger v. Busch (In re Busch), 311 B.R. 657 (2004), in which the United States Bankruptcy Court for the Northern District of New York discharged a sexual harassment judgment against a Chapter 7 debtor. The article thoroughly discusses how courts across the country have treated sexual harassment judgments under the "willful and malicious" exception to discharge found in Section 523(a)(6), pointing out how the United States Supreme Court's attempt to clarify this exception has had little effect. The author highlights the shortcomings of the Busch decision, and ultimately concludes that the Busch court's reasoning should be rejected in South Carolina.