United Mine Workers of America Combined Benefit Fund v. Toffel, No. 16-13483 (11th Cir. 2018)Annotate this Case
Debtor Walter Energy petitioned for Chapter 11 bankruptcy and sought to sell substantially all of its assets as a going concern. The bankruptcy court exercised its authority under the Retiree Benefits Bankruptcy Protection Act of 1988 (RBBPA) and terminated Walter Energy's obligation to pay premiums. The Funds appealed to the district court, which affirmed the bankruptcy court's judgment.
The Eleventh Circuit affirmed, and held that the bankruptcy court had the authority to modify the premiums that Walter Energy owed the Funds. The panel held that the RBBPA authorized the bankruptcy court to terminate Walter Energy’s obligation to pay premiums, even though the premiums were imposed by statute and Walter Energy was pursuing liquidation under Chapter 11, not a classic reorganization.