## Facts

- Robert William Kras, an indigent debtor, filed a voluntary bankruptcy petition and sought a discharge of debts.
- Federal law conditioned discharge on payment in full of required bankruptcy fees, totaling no more than $50.
- Kras lived with his family on public assistance and minimal supplemental income.
- A lower court found he could not realistically save the filing fee even over a year.
- Kras challenged the constitutionality of conditioning a bankruptcy discharge on payment of fees.

## Issues

1. Whether the Fifth Amendment’s Due Process Clause requires waiver of federal bankruptcy filing and related fees for indigent debtors seeking a discharge.
2. Whether conditioning access to a bankruptcy discharge on payment of fees violates equal protection principles applied to federal action through the Fifth Amendment.

## Decision

- The Supreme Court reversed the district court and upheld the fee requirement.
- The Court held the Constitution does not require the federal government to waive bankruptcy fees for indigent persons.
- The Court distinguished the divorce-fee access holding in *Boddie*, emphasizing that bankruptcy does not involve a fundamental interest and courts are not the exclusive avenue of relief in the same way.
- Because there is no constitutional right to a bankruptcy discharge, the fee scheme was reviewed under rational basis and sustained as rationally related to legitimate governmental interests (including defraying administrative costs).
- Dissents would have treated the fee as an unconstitutional barrier for those with no realistic alternatives to obtain meaningful debt relief.

## Legal Principles

- There is no constitutional right to a discharge of debts in bankruptcy; discharge is a statutory benefit subject to reasonable conditions.
- Conditioning access to a statutory benefit on payment of modest administrative fees generally does not trigger heightened scrutiny absent a fundamental right or suspect classification.
- *Boddie* is limited to contexts involving a recognized fundamental interest and state control over the sole practical forum for relief.
- Equal protection constraints on federal action operate through the Fifth Amendment’s Due Process Clause; economic classifications affecting indigents typically receive rational-basis review.

## Conclusion

The Court held that Congress may condition bankruptcy discharge on payment of required fees and that indigency alone does not create a constitutional entitlement to a fee waiver, because bankruptcy discharge is not a fundamental right and the fee requirement satisfies rational-basis review.


United States v. Kras, 409 U.S. 434 (1973)