Placid Oil Co. v. Williams (In re Placid Oil Co.), 463 B.R. 803

Placid Oil Company filed a post-confirmation adversary proceeding to determine if certain post-confirmation asbestos claims were discharged by the Confirmation Order.
The Post-Confirmation Tort Claimants allege Mrs. Williams contracted mesothelioma from exposure to asbestos tied to Mr. Williams’ work at the Black Lake Facility, resulting in death in 2003 and related damages.
Placid's bankruptcy case closed after confirmation in 1988; the discharge injunction generally bars pre-petition claims, raising whether these post-confirmation claims existed pre-petition and were discharged.
Dispute centers on whether the Post-Confirmation Tort Claimants had a pre-petition ‘claim’ under 11 U.S.C. § 101(5)(A) and whether notice to unknown creditors satisfied due process.
The court concludes pre-petition dischargeable claims existed, that the claimants were unknown creditors at the time of confirmation, and that publication notice was sufficient to discharge their claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the Post-Confirmation Tort Claimants have pre-petition claims against Placid?	Williams claimants had pre-petition exposure leading to a cognizable claim.	No pre-petition claim existed due to unknown status and reliance on a post-petition injury.	Yes; pre-petition claims existed under 101(5)(A).
Was proper due process notice provided to discharge the Post-Confirmation Tort Claimants' claims?	Unknown creditors require publication notice; Placid complied.	Actual notice or a future claims representative might be necessary.	Publication notice was sufficient; due process satisfied.
Should the Post-Confirmation Tort Claimants' claims be barred by the discharge order?	Their claims arose pre-petition and were discharged.	Unknown creditors might require different handling; not clearly discharged.	Yes; the Post-Confirmation Tort Claimants were discharged.

Lemelle v. Universal Mfg. Corp. (In re Lemelle), 18 F.3d 1268 (5th Cir. 1994) (broad 'claim' definition and pre-petition relationship test in bankruptcy)
In re Crystal Oil Co., 158 F.3d 291 (5th Cir. 1998) (unknown creditors and notice principles; pre-petition knowledge)
Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (U.S. 1950) (due process notice standard for beneficiaries of a trust or proceeding)
In re Egleston, 448 F.3d 803 (5th Cir. 2006) (pre-petition relationship test and claim construction context)
In re Chateaugay Corp., 2009 WL 367490 (Bankr.S.D.N.Y. 2009) (post-confirmation asbestos claims; consideration of future claims representative)