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Harris v. Trustees of Conneaut Lake Park, Inc. (In re Trustees of Conneaut Lake Park, Inc.)

Citations: 563 B.R. 784; 2017 Bankr. LEXIS 300; 63 Bankr. Ct. Dec. (CRR) 180Docket: Bankruptcy No. 14-11277-JAD; Adversary No. 16-1039-JAD

Court: United States Bankruptcy Court, W.D. Pennsylvania; February 3, 2017; Us Bankruptcy; United States Bankruptcy Court

Narrative Opinion Summary

This case involves the dismissal of an Adversary Proceeding brought by the Plaintiff, representing various trusts, against the Trustees of Conneaut Lake Park, Inc. (TCLP), seeking ownership of certain assets and injunctive relief. The Plaintiff's claims centered on replevin actions to recover amusement park rides and water company assets, with a complex procedural history dating back to prior equity and replevin actions in state courts. The Court evaluated the Defendant's Motion to Dismiss based on statute of limitations defenses, asserting that the Plaintiff's claims were filed well beyond the two-year limit prescribed by Pennsylvania law. The Plaintiff, Gary Harris, contended that the statute of limitations should be tolled due to his incarceration and custodianship conditions; however, the court rejected these arguments, citing state law that does not permit such tolling. The court concluded that the Plaintiff's claims were time-barred and dismissed the Complaint with prejudice, also disallowing the related proof of claim for $1,430,000.30. Jurisdiction was established under 28 U.S.C. § 1334, and the proceeding was deemed core. The decision effectively extinguished the Plaintiff's rights to the assets in question, affirming TCLP's ownership under the statute of limitations and res judicata principles.

Legal Issues Addressed

Application of Res Judicata

Application: The court dismissed the Plaintiff's Motion to Release Personal Property in 2005 based on res judicata, affecting the current proceedings.

Reasoning: In 2005, Mr. Harris filed a Motion to Release Personal Property within the Equity Action, which was denied on March 18, 2005, based on res judicata and lack of standing.

Federal Rule of Civil Procedure 12(b)(6)

Application: The court found that the Plaintiff's Complaint failed to state a claim upon which relief can be granted under Rule 12(b)(6).

Reasoning: Under Fed. R. Civ. P. 12(b)(6), a complaint can be dismissed for failing to state a claim upon which relief can be granted.

Jurisdiction and Core Proceedings

Application: The court exercised jurisdiction over the Adversary Proceeding under 28 U.S.C. § 1334, deeming it a core proceeding.

Reasoning: Jurisdiction for the Adversary Proceeding is established under 28 U.S.C. § 1334, and it is deemed a core proceeding, allowing the Court to issue a final judgment as per 28 U.S.C. § 157(b)(2).

Statute of Limitations in Replevin Actions

Application: The court applied Pennsylvania's two-year statute of limitations for replevin actions to dismiss the Plaintiff's claims as time-barred.

Reasoning: Under Pennsylvania law, the statute of limitations for replevin is two years.

Tolling of Statute of Limitations

Application: The Plaintiff's argument for tolling the statute of limitations due to incarceration and custodianship was rejected under Pennsylvania law.

Reasoning: Despite this, Harris disputes the statute of limitations defense, asserting that it should be tolled due to his incarceration during part of the custodianship and the custodianship's existence itself. However, Pennsylvania law explicitly states that imprisonment does not extend the statute of limitations.