United States Pipe and Foundry Company LLC, et al. v. Michael H. Holland, et al., No. 20-13832 (11th Cir. 2022)
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The Eleventh Circuit addressed whether a bankruptcy plan of reorganization confirmed in 1995 discharged the obligation of three debtor companies to provide future health-care benefits to retired employees of a coal company that was once part of the same corporate family. After the coal company’s future obligations to the retirees were discharged, the trustees of two healthcare benefit funds sued to compel the related companies to pay for the benefits. The bankruptcy court and district court ruled that the 1995 plan of reorganization did not discharge the claims for future benefits.
On appeal, the parties dispute whether the companies’ Coal Act obligations were discharged by the 1995 order confirming the companies’ plan of reorganization. The Eleventh Circuit reversed the district court’s holding and found that because the companies’ obligations to provide health-care benefits were fixed before the bankruptcy court confirmed the plan of reorganization, the Trustees’ claims for future retiree benefits were discharged in 1995. The court reasoned that the Trustees held a “claim” in 1995 because they had a “fixed” “right to payment.” Further, the Trustees’ claim under Section 9711 and resulting claims for 1992 plan premiums were discharged in 1995.
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