" The combination of students who do not complete college and private colleges that do not deliver degrees that help their graduates gain employment in the FTE sector has left many poor students still in the low-wage sector but now burdened with student debts. These debts cannot be discharged unless the former student can demonstrate 'undue hardship' from the loan. The statute does not define 'undue hardship,' and many courts use the Brunner test, derived from a 1987 opinion. This standard includes persistent poverty and a good-faith effort to pay the loan. In the view of some more recent opinions, this standard further requires hopelessness that conditions will improve. In other words, the students faces a double-bind: if she tries to transition to the FTE sector, she is hampered by her student loans. Only if she foregoes this ambition can the student loan be discharged. In New jersey, even death may not bring a reprieve from student loans. "

― Peter Temin , The Vanishing Middle Class: Prejudice and Power in a Dual Economy