A recent study found that a quarter million student debtors file for bankruptcy each year. Of these, approximately 450 attempted to seek a discharge in 2017 by arguing that their loan was not an "educational benefit" as defined by section 523(a)(8) of the bankruptcy code, or they successfully argue that the debt creates an "undue hardship". Of the completed cases, more than 60% were able to discharge their debts or achieve a settlement. The study concludes that the data shows: Creditors are settling unfavorable cases to avoid adverse precedent and litigating good cases to cultivate favorable precedent. Ultimately, this litigation strategy has distorted the law and cultivated the myth of nondischargeability. The study found that debtors who obtain favorable outcomes do not possess unique characteristics differentiating them from debtors who fail to seek student loan discharges and estimates that 64,000 individuals that filed for bankruptcy in 2019 would have met the undue hardship standard. It concludes that "about half of all bankrupt student loan debtors would obtain relief if they took the appropriate legal steps" and that "nearly everyone has bought into the myth that student loans are not dischargeable" and therefore most debtors do not take those steps.