Skip to main content

§ 1114

Roman Catholic Church of the Archdiocese of New Orleans, n re

Ruling
Debtor diocese failed to carry its burden of showing necessity for post-petition payment ofpre-petition general maintenance obligations to retired priests credibly accused of abuse.(Bankr. E.D. La.)
Issue(s)
Payment of Insurance Benefits to Retired Employees; Payment and Modification.

ABI Membership is required to access the full summary of Roman Catholic Church of the Archdiocese of New Orleans, n re Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on August 31, 2022 , LexisNexis #1122-020

Westmoreland Coal Co., In re

Ruling
Bankruptcy court properly held that debtor's Coal Act obligations under the Coal IndustryRetiree Health Benefit Act of 1992 were "retiree benefits" and could be modified. (5th Cir.)
Issue(s)
Payment of Insurance Benefits to Retired Employees.

ABI Membership is required to access the full summary of Westmoreland Coal Co., In re Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

:
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on August 04, 2020 , LexisNexis #0920-044

In re Northern New Eng. Tel. Operations LLC

Ruling
City's motion for payment of taxes for which it had not filed timely proofs of claim and filed after confirmation disallowed as untimely and extinguished.
Issue(s)
Was city entitled to payment of taxes for which it did not file timely proofs of claim pursuant to motion filed after confirmation?

ABI Membership is required to access the full summary of In re Northern New Eng. Tel. Operations LLC Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on February 11, 2014 , LexisNexis #0314-025

In re Chemtura Corp.

Ruling
Modification or termination of post-employment benefit plans for debtor's former executives allowed over objections with the exception of provision for medical and dental coverage.
Procedural posture

Chapter 11 debtors filed a motion for entry of an order authorizing the modification or termination of certain post-employment benefit plans. Six former executives filed objections.

ABI Membership is required to access the full summary of In re Chemtura Corp. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on April 08, 2011 , LexisNexis #0511-096

Visteon Corp. v. Visteon Corp.

Ruling
Bankruptcy and district courts erred in allowing debtor to terminate retiree benefit plans that were terminable at will without complying with §1114.
Procedural posture

Appellee chapter 11 debtor moved for permission to terminate retiree benefit plans. The bankruptcy court granted the motion as to most retiree benefits without requiring compliance with the procedures set forth in 11 U.S.C.S. § 1114. The United States District Court for the District of Delaware affirmed. Appellant union appealed.

ABI Membership is required to access the full summary of Visteon Corp. v. Visteon Corp. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on July 13, 2010 , LexisNexis #0910-128

In re Arclin US Holdings Inc.

Ruling
Medical benefits provided to debtor's former employee as part of early retirement package could not be modified.
Procedural posture

The creditor, a former employee of one of the debtors who took early retirement, asked for reinstatement of certain payments and medical benefits that the debtors had been paying to him pursuant to his prepetition separation agreement, as governed by 11 U.S.C.S. § 1114(a).

ABI Membership is required to access the full summary of In re Arclin US Holdings Inc. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on October 09, 2009 , LexisNexis #1109-061

In re Delphi Corp.

Ruling
Debtor authorized to terminate employee benefits concurrent with order for appointment of committee of retired employees.
Procedural posture

Debtor and certain subsidiaries and affiliates (debtors) asked the court to confirm their authority to terminate posthaste certain employee benefits including eliminating eligibility for employer-paid post-retirement health care benefits for certain salaried employees, ceasing contributions to other health care accounts, and terminating other similar benefits. Other interested parties moved for the appointment of a committee of retired employees.

ABI Membership is required to access the full summary of In re Delphi Corp. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on February 25, 2009 , LexisNexis #0509-105

McMillan v. LTV Steel Inc.

Ruling
Employee's administrative expense claim for retirement benefits properly denied as he became entitled to the benefits prior to petition date.
Procedural posture

Debtor employer filed a voluntary petition for chapter 11 bankruptcy. Plaintiff retired employee was granted leave to file administrative expense claims for unpaid pension funds, severance benefits, and backpay under 11 U.S.C.S. § 503(a). The District Court for the Northern District of Ohio upheld the bankruptcy court's denial of the employee's claim based on the employer's objection. The employee appealed.

ABI Membership is required to access the full summary of McMillan v. LTV Steel Inc. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on February 05, 2009 , LexisNexis #0309-103

Official Comm. of Unsecured Creditors of Tower Automotive v. Debtors & Debtors in Possession (In re Tower Automotive Inc.)

Ruling
Settlement with unions and retirees establishing trust and guaranteeing minimum 20% recovery was proper and in best interests of all parties.
Procedural posture

After filing a motion to reject collective bargaining agreements pursuant to 11 U.S.C. § 1113 and to modify retiree benefits pursuant to 11 U.S.C. § 1114, appellee debtor reached retiree settlements with appellee unions and appellee retiree committee. Appellant creditors committee, which had supported the debtor's 11 U.S.C. §§ 1113 and 1114 motion, sought review of orders of the bankruptcy court approving the settlements.

ABI Membership is required to access the full summary of Official Comm. of Unsecured Creditors of Tower Automotive v. Debtors & Debtors in Possession (In re Tower Automotive Inc.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

opinion summary, case decided on December 15, 2006 , LexisNexis #0207-032

In re A.C.E. Elevator Co.

Ruling
Payment of delinquent employee benefit plan contributions ordered subject to determination of extent contributions were entirely in respect of benefits for retirees, spouses and dependents.
Procedural posture

Creditor trustees of a multiemployer employee benefit plan moved for an order directing the debtor employer to pay delinquent plan contributions, interest, liquidated damages, and attorney's fees and costs, asserting such costs were expenses entitled to administrative priority under 11 U.S.C. §§ 365(b)(1), 503(b)(1)(A), 507(a)(1), 1113(f) and 1114(e).

ABI Membership is required to access the full summary of In re A.C.E. Elevator Co. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

opinion summary, case decided on June 23, 2006 , LexisNexis #1006-032