There is no limit on the number of times you can file bankruptcy. But the Bankruptcy Code imposes waiting periods between discharge in one case and eligibility for discharge in the next. If you file too soon, you can still file the case -- you just will not receive a discharge, which defeats the purpose.

The Waiting Period Table

The timelines below are measured from the filing date of the prior case to the filing date of the new case. The clock starts on the day the earlier petition was filed, not the day the discharge was entered.

Prior CaseNew CaseWaitStatute
Chapter 7Chapter 78 years727(a)(8)
Chapter 7Chapter 134 years1328(f)(1)
Chapter 13Chapter 132 years1328(f)(2)
Chapter 13Chapter 76 years*727(a)(9)
Chapter 11Chapter 7See noteNo specific bar
Chapter 12Chapter 132 years1328(f)(2)

* The 6-year bar after Chapter 13 does not apply if you paid 100% of unsecured claims, or paid at least 70% of unsecured claims under a plan proposed in good faith with best effort.

What Is Section 1328(f)?

Section 1328(f) is the provision that blocks a Chapter 13 discharge if you received a prior discharge too recently. It was added by the 2005 BAPCPA amendments. If you filed Chapter 7 and received a discharge, you must wait 4 years before you can receive a Chapter 13 discharge. If you filed Chapter 13 and received a discharge, you must wait 2 years.

Our free 1328(f) screening tool checks this automatically against 4.9 million federal cases.

What Is Section 727(a)(8)?

Section 727(a)(8) bars a Chapter 7 discharge if you received a Chapter 7 discharge in a case filed within the preceding 8 years. This is the most common waiting period people encounter when filing bankruptcy a second time.

What If My Prior Case Was Dismissed?

A dismissal does not produce a discharge, so the waiting-period rules above do not apply. You can generally refile after a dismissal without waiting for the discharge clock to run. However, Section 109(g) may impose a 180-day refiling bar in certain circumstances, and the automatic stay in your new case may be limited.

Our data shows this matters. Analysis of 4.9 million federal bankruptcy cases reveals that an estimated 75,764 cases may involve Section 1328(f) timing violations -- cases where a discharge was granted despite the waiting period not having elapsed. No federal court currently screens for this automatically.

The "Chapter 20" Strategy

Some debtors file Chapter 7 first to discharge unsecured debts, then file Chapter 13 to deal with secured debts like a mortgage or car loan through a payment plan. This is informally called a "Chapter 20" (7 + 13). It is legal, but the Chapter 13 filing must wait 4 years to receive a discharge. Even without a discharge, the Chapter 13 can still be useful for restructuring secured debt through the plan.

Practical Considerations