Meadows v. AMR Corp. (In Re AMR Corp.)
662 F. App'x 77
| 2d Cir. | 2016Background
- Creditor-appellant Lawrence M. Meadows filed a timely proof of claim in AMR Corporation’s bankruptcy and later sought to amend it to add discrimination and whistleblower (statutory) claims that were otherwise untimely.
- The Bankruptcy Court disallowed and expunged three of Meadows’s amended proofs of claim as untimely and denied leave to amend; the District Court affirmed; Meadows appealed pro se to the Second Circuit.
- Bankruptcy court found Meadows unjustifiably delayed in pursuing statutory claims, and that allowing amendment would prejudice the debtor by disrupting an omnibus settlement with the Allied Pilots Association (APA) and risk opening the floodgates to other claimants.
- Meadows argued his delay was attributable to prior counsel and that the bankruptcy court denied him due process by restricting his testimony and modifying an oral order in writing.
- The Second Circuit reviewed legal questions de novo and factual findings for clear error, and reviewed denial of amendment for abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether untimely statutory claims may relate back to the timely disability claim | Meadows: discrimination/whistleblower claims relate back to his timely long-term disability claim (and/or relate via APA omnibus claim) | Debtor/Bankruptcy court: relation back not established; amendment would be inequitable and prejudicial | Relation back not established as to Meadows; even if relation back were assumed, amendment would be inequitable and denial not an abuse of discretion |
| Whether excusable neglect justifies late amendment | Meadows: delay caused by prior counsel, excusing lateness | Debtor: Pioneer and Enron principles bar counsel mistakes from excusing delay; delay unjustified | Court: counsel mistakes do not ordinarily excuse late filing; no excusable neglect shown |
| Whether bankruptcy court abused discretion in limiting Meadows’ testimonial presentation | Meadows: court improperly refused to let him refute APA witness testimony by oral testimony | Debtor: court allowed affidavit and limited oral testimony to avoid confusion/waste; within discretion | Court: limiting oral testimony and permitting affidavit was proper exercise of discretion; no prejudice shown |
| Whether written modification of oral order denied Meadows due process | Meadows: written order altered his rights to pursue grievance | Debtor: written language merely limited pursuit to what law permits; no additional restriction | Court: Meadows showed no authority that written wording caused prejudice; no due process violation |
Key Cases Cited
- In re Lehman Bros. Holdings Inc., 761 F.3d 303 (2d Cir. 2014) (standard of review: legal conclusions de novo, factual findings for clear error in bankruptcy appeals)
- In re Enron Corp., 419 F.3d 115 (2d Cir. 2005) (relation-back and excusable neglect principles for amending proofs of claim)
- In re Smith, 507 F.3d 64 (2d Cir. 2007) (abuse-of-discretion standard for bankruptcy court decisions)
- Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P'ship, 507 U.S. 380 (1993) (attorney error generally does not constitute excusable neglect for filing deadlines)
- Meadows v. AMR Corp., 539 B.R. 246 (S.D.N.Y. 2015) (district court opinion affirming bankruptcy court denial of Meadows’s amendments)
- In re Busy Beaver Bldg. Ctrs., Inc., 19 F.3d 833 (3d Cir. 1994) (bankruptcy judge has discretion to limit oral testimony at hearings)