Narrative Opinion Summary
General Motors LLC (GM) initiated an adversary proceeding against the Manville Personal Injury Settlement Trust, seeking a declaratory judgment that its state court action in Ohio is not barred by the channeling injunction from the Johns-Manville Corporation's chapter 11 plan. The Manville Trust moved to dismiss, arguing that GM's claims are precluded by the channeling injunction and Trust Distribution Procedures (TDP). The court established jurisdiction under 28 U.S.C. §§ 1334(a) and 157(a) and found GM's claims enjoined by the channeling injunction. The injunction, which arises from the 1982 Johns-Manville bankruptcy, directs all asbestos-related claims to specific trusts, preventing litigation against the Debtors. GM's lawsuit in Ohio, seeking recovery for a subrogation interest from a workers' compensation claim, was stayed pending resolution in bankruptcy court. The court exercised its discretion to issue a declaratory judgment, affirming that GM's legal actions are barred by the injunction and TDP, and requiring compliance with the Trust's established procedures. Consequently, GM is prohibited from pursuing the Manville Trust in the Ohio action, both as a subrogee and for contribution, under the terms of the Manville Plan and the Ohio Revised Code 4123.931.
Legal Issues Addressed
Channeling Injunction under Bankruptcy Plansubscribe to see similar legal issues
Application: The court determined that GM's claims against the defendants are enjoined by the channeling injunction of the Manville Plan.
Reasoning: The court, adhering to its prior ruling from a July 2017 hearing, determined that GM's claims against the defendants are indeed enjoined.
Declaratory Judgment and Jurisdiction Reservationsubscribe to see similar legal issues
Application: The court exercised its discretion to issue a declaratory judgment, noting its reserved jurisdiction to interpret disputes related to the Manville Plan.
Reasoning: The Court, however, affirms its discretion to issue a declaratory judgment, noting that the Manville Confirmation Order reserves jurisdiction for interpreting disputes related to the Manville Plan and associated agreements.
Jurisdiction under 28 U.S.C. §§ 1334(a) and 157(a)subscribe to see similar legal issues
Application: The court established jurisdiction over the adversary proceeding as a core proceeding related to estate administration.
Reasoning: Jurisdiction is established under 28 U.S.C. §§ 1334(a) and 157(a), categorizing this as a core proceeding related to estate administration.
Ohio Revised Code 4123.931 and Subrogation Interestsubscribe to see similar legal issues
Application: The Ohio Code requires claimants to notify GM of settlements, and failure to do so results in joint liability for subrogation interests.
Reasoning: The statute stipulates that settlements are not final unless prior notice is provided, and failure to do so results in joint liability for the full subrogation amount.
Prohibition of Legal Actions under Trust Distribution Procedures (TDP)subscribe to see similar legal issues
Application: GM is barred from initiating lawsuits against the Manville Trust under the TDP, and any claims must comply with the Trust's governing documents.
Reasoning: Consequently, GM is barred from suing the Manville Trust in the Ohio Action, with its rights strictly confined to the terms of the TDP.