While it is difficult to discharge student debt in bankruptcy, it is not impossible.  The "Brunner test"  was recently applied in the Southern District of New York, discharging student debt in excess of $200,000.   This standard has been successfully applied in the Western District of New York as well.  

While the specific facts of each case do matter, an additional factor to consider is that the discharge of student loans in bankruptcy require the filing of an  "adversary proceeding" or lawsuit against the lender. Like any lawsuit, this means time and money to prove the debtor meets the Brunner standard.  

As an alternative, some lenders are willing to apply the Brunner standard administratively and without the time and cost of a lawsuit.  Again, the facts of each case are treated separately.