In the 1988 case In re McDonald, the United States Supreme Court ruled on a matter of bankruptcy law. The petitioner, Robert L. McDonald Jr., had filed for Chapter 7 bankruptcy and sought to discharge his student loan debt. However, under U.S Bankruptcy Code Section 523(a)(8), educational loans are not dischargeable unless repaying them would impose an "undue hardship" on the debtor or their dependents. The court held that in order to prove undue hardship, a debtor must show more than temporary financial difficulty; they must demonstrate that they have made good faith efforts to repay their loans but due to factors beyond their control such as illness or disability, repayment is likely impossible now and in the future. As McDonald was unable to meet this standard of proof - he was young with many potential earning years ahead of him and had not made substantial efforts at repayment - his request for discharge was denied.

The dissenting opinion in the In re McDonald case argued that the majority's decision to deny habeas corpus relief was incorrect. The dissent believed that there were significant issues with how the trial court handled evidence, particularly regarding a key witness who had initially provided an alibi for McDonald but later changed her testimony. They felt this change of heart was not adequately explained or scrutinized during the trial and could have influenced its outcome significantly. Furthermore, they disagreed with how the prosecution used prior convictions as character evidence against McDonald, arguing it unfairly prejudiced his defense. The dissent also took issue with instructions given to jurors about reasonable doubt and thought these may have confused them into thinking they needed more certainty than is actually required to acquit someone on criminal charges. Overall, they believed these errors combined might well have resulted in an unfair trial for McDonald.