The court also heard arguments [transcript, PDF] in Bullock v. Bank Champaign, NA [JURIST report] to consider what degree of misconduct by a trustee will disqualify a debt made by the trustee from discharge under the Bankruptcy Code [11 USC § 523(a)(4)]. The case hinges on the word defalcation [definition], which has remained undefined in the code through all amendments since 1841. The attorney for Randy Curtis-Bullock argued that his client did not have mens rea necessary to commit defalcation—which he argued should have been "extreme recklessness or conscious misbehavior by the actor"—and thus the debt he incurred when he mishandled being a trustee should be dischargeable. The attorney for Bank Champaign [corporate website] argued that other parts of the code—including sections barring debts from discharge due to fraud, embezzlement and willful and malicious injury—suggest that no mental intent is required for bad acts, including defalcation.