The Michigan Court of Appeals in a recent unpublished opinion, held that debts which are not included in debtors' bankruptcy schedules are not discharged in the bankruptcy so creditors are free to collect the debt. The court's decision is unpublished so it has limited precedent value, and could be appealed, so stay tuned.

Still, the decision is somewhat surprising as a 1998 Sixth Circuit Court of Appeals case has held that unscheduled debts in Chapter 7 no-asset bankruptcy cases are discharged even though the creditor was not given notice of the bankruptcy.