Ransom v. FIA Card Services, N. A., 562 U.S. 61 (2011), is a decision by the Supreme Court of the United States involving the means test in Chapter 13 of the United States Bankruptcy Code. The means test had been adopted by the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005, and Ransom is one of several cases in which the Supreme Court addressed provisions of that act. The means test determines how much disposable income debtors have to pay back their creditors, and permits debtors to shield some income from creditors for expenses based on cost tables prepared by the Internal Revenue Service. The Court ruled in Ransom, primarily in reliance on supplemental commentary authored by the IRS, that a car-ownership cost allowance was available only to debtors who made loan or lease payments on a vehicle. This judgment resolved a circuit split regarding the allowance between the Ninth Circuit, which the Supreme Court affirmed in this case, and three other circuits that had all ruled the allowance applied even to debtors who owned their cars outright. The Court's opinion was delivered by Justice Elena Kagan, who was confirmed to the Court on August 7, 2010. The opinion was not only her first as a Supreme Court justice but also as a judge, and her participation in the case's oral argument, which was held on the first day of the Court's 2010 term, had also been her first. Justice Antonin Scalia, the sole dissenter, criticized the Court for using the supplemental commentary on the tables when the Bankruptcy Code only incorporated the tables but not the commentary. Background of the case The Chapter 13 means test Congress enacted the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA) to address perceived abuses of the bankruptcy system. One of the biggest changes, called the "heart" of the Act's "bankruptcy reforms," was the adoption of the means test for use in Chapter 13 bankruptcy proceedings. Chapter 13 requires debtors to submit a repayment plan for court approval to obtain a discharge of their debts. The means test is a statutory formula that determines how much income the debtor can use for debt repayment, to ensure that debtors pay back as much as feasible. It permits debtors to shield a portion of their income from creditors based on "reasonably necessary" living expenses, which are calculated from claimed allowances for defined