United States Pipe And Foundry Company LLC, et al.v.Michael H. Holland, et al.
Three related companies’ bankruptcy reorganization was confirmed in 1995, after the Coal Act made them responsible for retiree health benefits and premiums because of their pre-bankruptcy relationship to a coal-company signatory. After their former corporate affiliate stopped providing coverage in 2016, trustees sought Combined Fund and 1992 Plan premiums and direct retiree coverage under an individual employer plan. The Eleventh Circuit held that the companies’ Coal Act obligations were claims discharged by the 1995 plan: their liability was fixed by pre-confirmation conduct even though future amounts were uncertain or not yet due. The court also held that the trustees’ right to compel coverage was a bankruptcy claim because the same breach could create a right to premium payments under the 1992 Plan. It reversed the judgment for the trustees and remanded. Judge Anderson agreed that Combined Fund premiums were discharged but dissented as to the coverage obligation and 1992 Plan premiums.
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