Skip to main content

§ 1141(d)(1)

In re Taylor

Ruling
Bankruptcy court erred in issuing contempt order where no violation of the discharge injunction had occurred.
Issue(s)
Whether the bankruptcy court erred in entering a civil contempt order for creditor's alleged violation of the discharge injunction?

ABI Membership is required to access the full summary of In re Taylor 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
Consumer opinion summary, case decided on July 20, 2015 , LexisNexis #0815-062

In re National Heritage Found. Inc.

Ruling
Creditor and attorney held in contempt for filing postconfirmation civil lawsuit to collect discharged debts.
Procedural posture

Chapter 11 debtor filed a motion for contempt and sanctions against respondents, creditors and their counsel, based on respondents' filing of a class action suit against the debtor and its officers and directors.

Issue(s)
Whether creditors and their attorneys should be held in contempt because they filed a civil action against a corporate debtor and its officers and directors after the court entered an order in the debtor's chapter 11 bankruptcy case which confirmed the debtor's plan.

ABI Membership is required to access the full summary of In re National Heritage Found. 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 June 21, 2013 , LexisNexis #0713-130

Capco Energy Inc. v. McMoRan Oil & Gas LLC (In re Capco Energy)

Ruling
Creditor entitled to summary judgment against debtors, though not estate, for gas balancing despite failure to file timely proof of claim.
Procedural posture

Debtors brought an adversary proceeding against defendant creditor. Each had owned working interests in mineral production of a well. The creditor filed a crossclaim against the purchaser of the debtors' working interest, asserting it was liable for approximately $336,683.57 of gas imbalance from sales of production. Those parties submitted cross motions for summary judgment.

ABI Membership is required to access the full summary of Capco Energy Inc. v. McMoRan Oil & Gas LLC (In re Capco Energy) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on January 04, 2011 , LexisNexis #0211-030

In re UAL Corp.

Ruling
Bankruptcy court erred in holding that terminated employee's postpetition, preconfirmation cause of action for discrimination was not barred by discharge.
Procedural posture

The matter was before the court upon the cross-appeals of debtor and a terminated employee of the decision of the U.S. Bankruptcy Court for the Northern District of Illinois denying debtor's motion to hold the terminated employee and his counsel in contempt for suing debtor for employment discrimination in a California state court after confirmation of debtor's plan of reorganization was confirmed.

ABI Membership is required to access the full summary of In re UAL 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 October 29, 2008 , LexisNexis #1108-138

Humphrey-Baker v. United Airlines Inc.

Ruling
Employment discrimination action barred to extent predating debtor employer's plan confirmation.
Procedural posture

Defendant, a former employer of plaintiff employee, filed a motion for summary judgment in the employee's action, which alleged that the employer violated California's Fair Employment and Housing Act (FEHA), Cal. Gov't Code § 12940, by discriminating against her based on her physical disability and by failing to offer reasonable accommodations.

ABI Membership is required to access the full summary of Humphrey-Baker v. United Airlines 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 21, 2008 , LexisNexis #1108-139

Browning v. MCI Inc. (In re WorldCom Inc.)

Ruling
Prepetition state law right of action for trespass was discharged by plan confirmation.
Procedural posture

Appellant landowner challenged an order of the District Court for the Southern District of New York affirming an order of the Bankruptcy Court for the Southern District of New York granting the reorganized debtor-appellee corporation's motion to bar the landowner from prosecuting Kansas state law claims for trespass and unjust enrichment against the corporation following its emergence from a Chapter 11 proceeding.

ABI Membership is required to access the full summary of Browning v. MCI Inc. (In re WorldCom 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 October 14, 2008 , LexisNexis #1108-032

Northwestern Mutual Life Ins. Co. v. Delta Air Lines Inc. (In re Delta Air Lines Inc.)

Ruling
Bankruptcy court properly upheld debtor's objections to claims for payment under tax indemnification agreements where plan provision for payment with stock of reorganized debtor was forseeable.
Procedural posture

Appellee debtor, an airline, filed a petition under chapter 11 of the Bankruptcy Code, and appellant claimants filed claims seeking payment of approximately $ 1 billion based on tax indemnification agreements (TIAs) the debtor and the claimants entered. The Bankruptcy Court for the Southern District of New York upheld the debtor's objections to the claims, and the parties filed cross-appeals.

ABI Membership is required to access the full summary of Northwestern Mutual Life Ins. Co. v. Delta Air Lines Inc. (In re Delta Air Lines 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 September 29, 2008 , LexisNexis #1108-031

West v. WorldCom Inc.

Ruling
Action against debtor for continuing trespass related to maintenance of fiber optic cable was not discharged in bankruptcy.
Procedural posture

Petitioner property owner filed an action alleging trespass, slander of title, and unjust enrichment based on the installation of fiber optic cable within railroad rights of way. Respondent debtor filed for bankruptcy. The debtor sought a declaratory judgment that a discharge precluded the owner's action. The bankruptcy court granted the debtor's motion for summary judgment. The owner appealed.

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

opinion summary, case decided on February 13, 2007 , LexisNexis #0307-030

In re Worldcom Inc.

Ruling
Court affirmed ruling that causes of action arose prepetition and, thus, were discharged by confirmation of chapter 11 plan.
Procedural posture

Appellants appealed from an order of the bankruptcy court, which granted appellee debtor's motion to bar the prosecution of certain property-related claims initiated by appellants. The bankruptcy court ruled that any valid claims possessed by appellants were prepetition in nature and therefore had been discharged by the confirmation of debtor's plan of reorganization.

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

opinion summary, case decided on March 30, 2006 , LexisNexis #0406-137

Intl Paper Co. v. MCI Worldcom Network Serv.

Ruling
Confirmation of the reorganization plan discharged the prepetition trespass claim, and the court did not recognize a further postpetition claim of trespass.
Procedural posture

Plaintiff paper company sued defendant communications company, alleging state law claims of trespass, slander of title, and unjust enrichment. The District Court for the Western District of Arkansas granted summary in favor of the communications company. The paper company appealed. Presently before the court was the communications company's motion to dismiss the appeal.

ABI Membership is required to access the full summary of Intl Paper Co. v. MCI Worldcom Network Serv. 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
opinion summary, case decided on March 06, 2006 , LexisNexis #0306-098