it includes emotional and reputational harms, it does not go so far as to allow nonbankruptcy law to define certain torts as personal injury torts.” Id. The court in Ice Cream Liquidation rejected the narrow approach because, as shown by Section 522(d)(ll) of the Bankruptcy Code, Congress knew how to say “personal bodily injury” when it wanted to. 281 B.R. at 160. In addition, the narrow approach may put too much emphasis on a technical analysis of a complaint’s allegations, often drafted before the issue arises in a subsequent bankruptcy case. Id. The court also disagreed with the broad approach because it may place too much reliance on how a tort was categorized by nonbankruptcy law, increasing the risk that fina ion claim is a personal injury tort claim); Smith, 389 B.R. at 908 (<HOLDING>); Passialis, 292 B.R. at 352 (holding that a
holding that an embezzlement claim is not a personal injury tort claim holding that a claim for violation of the fair debt collection practices act is not a personal injury tort claim holding that a negligence claim is not a personal injury tort claim holding that a defamation claim is a personal injury tort claim holding that a libel claim is a personal injury tort claim