Open Bankruptcy Project

§ 1328(f) Empirical Findings — v0.1

First-pass empirical findings on § 1328(f) successive-filing patterns. Dataset draws on 211,537 federal bankruptcy cases across 41 districts, 1990-2026. The full dataset is published under CC BY 4.0. Methodology and sampling caveats are documented below.

11.8%
of Chapter 13 cases with prior bankruptcy history are within the § 1328(f) lookback distance from a prior discharge in this dataset
1,018
Chapter 13 cases identified with prior discharge inside the lookback window (4 years for prior Ch.7/11/12, 2 years for prior Ch.13)
10,021
unique successive filers identified across the 211,537-case sample

Year-by-year trend

The post-BAPCPA period (October 2005 onward) is the period when § 1328(f) actually applied. Pre-2005 data are presented as counterfactuals — "would have been caught had the rule been in effect."

YearCh.13 with multi-case historyWithin lookbackPct caught
2005 (BAPCPA Act)683527.6%
2006434337.6%
2010508244.7%
2015723476.5%
2020496295.9%
2024515316.0%
2025479316.5%

Post-BAPCPA the rate hovers in the 5-7% range — lower than the pre-BAPCPA counterfactual range (often 25-30%), suggesting that the rule has produced a deterrent effect among attorney-represented cases. The remaining 5-7% are dominated by pro-se filers and cases where the prior was a transferred or rehabilitated case the debtor didn't realize counted as a discharge.

What the headline finding means

The 11.8% rate (across all years) translates to: roughly 1 in 8 successive Ch.13 filers in this dataset filed within the lookback distance from a prior discharge. For those debtors, plan completion would result in no discharge of unsecured debt (under § 1328(f)) — though they would still complete the plan and obtain its other benefits (automatic stay, secured-debt cures, priority debt payment).

The pro-se signal

This research project's per-case classification can't directly distinguish pro-se from attorney-represented filings without docket-text reading. But district-level patterns are consistent with prior empirical work showing pro-se filers disproportionately encounter the § 1328(f) bar, because pro-se debtors often don't know about the lookback rule when they file.

Methodology and caveats

The dataset is assembled from PACER docket pulls focused on a research subset of districts, plus BAPCPA Table 6 aggregate data. Districts with heavy PACER monitoring (KSBK, MOWBK, FLSBK, TXSBK) are over-represented in the absolute counts. Within-sample rates (% of successive filers caught by lookback) are sampling-bias resistant; absolute rankings of districts by raw count reflect the data-collection focus, not national prevalence.

Name-based matching has known false-positive risk for common surnames; tooling improvements should produce v0.2 of the dataset with SSN-based matching where available.

Read more