A Maryland contractor officer failed to pay subcontractors from trust funds held under state law. When the contractor went bankrupt, subcontractors tried to collect from the officer personally, claiming the debt was non-dischargeable under federal bankruptcy law. The court ruled that individual officers cannot be held personally liable for trust law violations unless they intentionally defrauded someone, and that trusts created by wrongdoing don't count as real fiduciary relationships for bankruptcy purposes. This means subcontractors cannot automatically pursue officers personally for unpaid trust funds.
Personal liability against contractor officers for unpaid trust funds requires proof of intentional fraud—negligence or simple breach of the trust law is not enough
Maryland's construction trust statutes do not automatically create enforceable fiduciary duties that survive bankruptcy discharge