Meadows v. AMR Corp.
2015 U.S. Dist. LEXIS 137729
| S.D.N.Y. | 2015Background
- Meadows, a former American Airlines pilot, filed Proof of Claim No. 1916 by the bankruptcy bar date asserting $470,340 for “pilot long-term disability payments.”
- AMR (American's parent) filed chapter 11; the bankruptcy court set July 16, 2012 as the bar date for claims.
- The Allied Pilots Association (APA) timely filed a huge omnibus claim that included Grievance 12-011 (Meadows’s grievance); APA later settled with the debtors, extinguishing most grievances including Grievance 12-011.
- After the bar date, Meadows filed three amended proofs of claim (8, 18, and 20 months late) seeking at least $5 million and asserting ERISA, SOX, EEOC, and other statutory claims; the original claim contained no supporting documentation.
- The Bankruptcy Court disallowed the three amended claims as untimely, concluding they did not relate back to the original claim and that excusable neglect did not apply; the district court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether amended claims relate back to timely claim | Meadows: amended statutory claims relate back because they reference the original LTD claim and are natural offshoots | AMR: original claim only asserted LTD payments; amended claims raise distinct statutory claims and much larger damages, so no notice | Held: No relation back; original claim did not put debtor on notice of statutory claims or larger amount |
| Whether timely APA claim (Grievance 12-011) preserved Meadows’s statutory claims | Meadows: Grievance included statutory issues and was part of APA’s timely claim, so his claims were preserved | AMR: grievance process addresses narrow CBA issues; APA settlement extinguished grievances, so cannot preserve broad statutory claims | Held: APA claim/grievance did not preserve Meadows’s late statutory claims; permitting them would prejudice debtor |
| Whether amended claims should be allowed for excusable neglect | Meadows: delayed filings were reasonable because he relied on counsel/advice that grievance preserved claims | AMR: bar date was clear; delay was long and prejudicial; attorney error not excusable | Held: Excusable neglect not shown under Pioneer factors; Second Circuit precedent disfavors excusing clear bar-date failures |
| Procedural/evidentiary complaints and order modification | Meadows: Bankruptcy Court improperly limited evidence, favored APA counsel, and modified final order to his prejudice | AMR: court acted within discretion; modification did not prejudice Meadows and actually broadened arbitration scope | Held: No abuse of discretion; court allowed briefing and argument, exclusion of cumulative/confusing evidence proper, modification not prejudicial |
Key Cases Cited
- In re Enron Corp., 419 F.3d 115 (2d Cir. 2005) (two-step relation-back inquiry for amended proofs of claim and equitable factors for allowing amendments)
- Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P’ship, 507 U.S. 380 (1993) (standard for excusable neglect considers multiple equitable factors)
- Silivanch v. Celebrity Cruises, Inc., 333 F.3d 355 (2d Cir. 2003) (courts in Second Circuit apply a strict approach to Pioneer excusable-neglect analysis)
- In re Integrated Res., 157 B.R. 66 (S.D.N.Y. 1993) (trial court discretion governs amendments to timely-filed proofs of claim)