In a matter of first impression not yet addressed by any circuit court, the U.S. Court of Appeals for the Fourth Circuit in the case of Cantwell-Cleary v. Cleary Packaging (In re Cleary Packaging), 36 F.4th 509 (4th Cir. 2022) addressed whether the discharge exceptions under Section 523(a) apply to corporate debtors under Subchapter V of Chapter 11 of the Bankruptcy Code. Based on the text and purposes of Subchapter V, the Cleary court held that, unlike corporate debtors in traditional Chapter 11 cases, corporate Subchapter V debtors are subject to Section 523(a) to the same extent as individual debtors and, as such, can be denied a discharge.