The 9th U.S. Circuit Court of Appeals has ruled that the strict language of the 2005 bankruptcy reform law allows higher-income debtors to limit the amount of money and time for repayment of debts, though lower-income debtors do not share the same benefit.

Also, the 9th Circuit held that bankruptcy judges must stick to the terms of the 2005 bankruptcy reform law even though it treats higher-income debtors better than lower-income debtors when it comes to calculating income available to pay creditors in Chapter 13 reorganizations.