What is the test for "willful" injury?

As stated before, an injury is "willful" "when it is shown either that the debtor had a subjective motive to inflict the injury or that the debtor believed that injury was substantially certain to occur as a result of his conduct." In re Jercich, 238 F.3d at 1208 (emphasis in original). "Willful" intent does not require that the debtor had the specific intent to injure the creditor, if the act was intentional and the debtor knew that it would necessarily cause injury. Id. at 1207. "Willful" means "voluntary" or "intentional." Kawaauhau v. Geiger, 523 U.S. at 63, citing, Restatement (Second) of Torts, 8A, comment A (1964). This standard focuses on the debtor's subjective intent, and not "whether an objective, reasonable person would have known that the actions in question were substantially certain to injure the creditor." In re Su, 290 F.3d at 1145-1146.

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