Allstate did not appear for trial or meaningfully defend itself in the previous action." ), app. denied, 489 Mich. 858, 795 N.W.2d 8 (2011) and 795 N.W.2d 11 (2011) ( Nos. 141897 and 141899).          The court first asks, what is the " standard" in § 523(a) to which the standard applied in the underlying state-court action must be identical in order for the state-court judgment to have preclusive effect in federal bankruptcy court dischargeability proceeding?