“Once you have had a wonderful dog, a life without one is a life diminished” (Dean Koontz in A Big Little Life: A Memoir of A Joyful Dog)            

Some time ago, while serving as Chapter 13 Trustee, I administered a case that involved household cats.  During the Section 341 meeting a large monthly expense line item on Schedule J itemized for “pet food,” caught my eye. I recall $800 was listed on Schedule J for this expenditure.  To me this obviously was an unusually high amount.  When questioned, the debtor replied she really liked her cats.  I said that’s fine, however, I needed additional backup to justify the monthly amount.  I never did receive backup since soon after the meeting the debtor’s home was raided by the Delaware Office of Animal Welfare.  The debtor had been hoarding dozens and dozens of cats in her home. The neighbors called complaining about potentially hazardous conditions.  Many cats were rescued. Shortly thereafter, the debtor’s case was dismissed.

From then on, I reviewed the reasonableness of pet expenses.  Under the Means Test, there is no specific IRS Standards for pet care expenses.  These fall under the miscellaneous category.  Sometimes it is listed as a separate line item.  Usually, it is not an issue.  However, these days there are designer dogs and cats.  There are service animals.  Specialized and expensive pet food has become mainstream.  In recent years, veterinary medical expenses have skyrocketed.  Some debtors have purchased pet insurance with high premiums. There is no clear direction about what constitutes reasonable and necessary for debtor’s pet expenses.  In an article, “Barking Up the Wrong Tree: Pet Care Expenses in Bankruptcy,” the author in a sympathetic nod to pet ownership states “By recognizing the necessity of pet care expenses in consumer bankruptcy cases, bankruptcy courts can help support and encourage responsible pet ownership.” E. Hornbrook,33 APR Am. Bankr. J. 56 (2014).

Examples of what may be considered extraordinary, and not necessarily reasonable to maintain a pet:  excessive grooming costs; pet daycare, dog sitting, or boarding fees; premium pet food; or luxury animal toys, coats, and high-end accessories. Of course this is very subjective to each owner.  However, if challenged as to the amount of disposable income, it is the debtor’s burden to demonstrate reasonableness of the expense or necessity by special circumstances.

Reviewing some recent cases involving pet care expenses and reasonableness in bankruptcy:

In the context of a Chapter 7 case, the court held that $150 per month for pets was a reasonable expense.  The debtors had 3 dogs, one of which required medication.  They also had cats and chickens.  See In re: Lindesmith Case #24-40313 Bankr D. Kansas 2025.

Another case involving the dischargeability of a student loan, the court exhaustively reviewed the debtors’ income and expenses.  Included in the expense list was a line item of $265 per month for “Dogs.” The court found the debtors failed to satisfy the first prong of the “Brunner Test.”  Their expenses grossly exceeded those required to maintain a minimal standard of living.  The court did not however specifically mention the $265 per month for dogs. See In re: Eimers Case #18-20219 Bankr D. Kansas 2025

In the case of In re Chambers Bankr M.D. Florida 2022 WL 828301 the court, in reviewing a chapter 7 Motion to Dismiss for Abuse, held due to additional disposable income the case would be dismissed unless converted chapter 13.  However, while doing so, the court also addressed the debtor’s expenses including pet expenses and stated:

“The debtor, who was single, and has no children, testified that his dogs, both whom have medical conditions which require medications are like children to him. While not owning a pet is indeed a reasonable alternative, the debtor already owns his dogs. His only options at this point are to find another home for the dogs or to euthanize them, neither of which is a satisfactory option. In this situation, the court finds that the debtors additionally monthly pet expense of $100 is a special circumstance.”

Although a chapter 13 case was dismissed on other grounds (extravagant vacations and vehicles), $145 per month for pet care apparently was not an issue.  See In re Warwick 668 B.R. 555 Bankr. E.D. Tenn 2025.

A student loan dischargeability case holding against the debtor stated…” also pays over $100 per month in pet expenses and spends some amount of money on other recreation and entertainment activities. While debtors are entitled to some modest spending on entertainment, the court is doubtful that Hastings could successfully argue that these collective expenses reflect a frugal lifestyle.”  Surprisingly this was so even though the debtor’s daughter required a service dog.  See In re: Hastings 643 B.R. 470 Bankr. S.D, Ohio 2022.

There is no bright-line approach to provide a clear, objective, and predictable rule for expenses of a pet in a chapter 7 or chapter 13 bankruptcy case. What may be reasonable and necessary to a debtor, may be extravagant to a creditor, trustee, or a judge.  If appropriate, justification as a special circumstance may be pursued.  Debtors and their attorneys should be prepared to provide evidence justifying the expense due to the need as a service animal or emotional support pet. Ultimately, pet expenses in bankruptcy can be a deeply personal and emotional issue. All parties should approach the subject with appropriate sensitivity, understanding, and compassion. 

Printed with permission, NACTT Academy, Considerchapter13.org, October 20, 2025)