Roman Catholic Archbishop of Baltimore, 23-16969

The Roman Catholic Archbishop of Baltimore filed for Chapter 11 bankruptcy on September 29, 2023, in anticipation of a surge in child sexual abuse lawsuits following Maryland's elimination of the statute of limitations for such claims.
The bankruptcy triggered an automatic stay, halting most litigation against the debtor and entities covered under the debtor's insurance policies ("Covered Parties"), in order to preserve estate assets for the benefit of all claimants.
An Official Committee of Unsecured Creditors (UCC), largely comprising abuse survivors, has been actively involved, seeking clarification on the scope of the stay and its interplay with amended state law.
In April 2025, Maryland amended the Child Victims Act to lower caps on noneconomic damages for abuse survivors for actions filed on or after June 1, 2025, prompting time-sensitive legal concerns for survivors.
The UCC moved to clarify whether survivors could file civil complaints in state court to preserve their rights under the new law without violating the bankruptcy stay.
The bankruptcy court modified the automatic stay solely to allow the timely filing and serving of child sexual abuse complaints under Maryland law until May 31, 2025.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the automatic stay bar the filing/service of complaints before May 31, 2025?	Survivors should be able to file to preserve claims due to impending statutory cap changes.	Stay should protect estate and insurance from dissipation.	Stay modified to permit filing/service of state claims by May 31, 2025 only.
Scope of stay as applied to non-debtor "Covered Parties"	Need clarity to know exactly which entities are protected by the stay.	Estate assets (insurance) must be preserved for all.	Stay applies to entities covered by estate insurance, as listed in court's Schedule A.
Whether filing a proof of claim in the bankruptcy counts as an "action" under Maryland law	Filing a timely proof of claim should preserve the survivor's rights under state law.	No express view; unresolved by the court.	Court acknowledges but does not decide this issue.
Whether bankruptcy law tolls the limitations period under the CVA amendment	Limitations period should be tolled during bankruptcy.	No express view; unresolved by the court.	Court does not decide; rights preserved for later argument.

Law v. Siegel, 571 U.S. 415 (2014) (bankruptcy court cannot override explicit mandates of other Bankruptcy Code provisions)
In re Waldron, 785 F.2d 936 (11th Cir. 1986) (bankruptcy laws are shield, not sword)
In re Robbins, 964 F.2d 342 (4th Cir. 1992) (three-factor test for modifying automatic stay in bankruptcy)
In re Joyner, 416 B.R. 190 (Bankr. M.D.N.C. 2009) (stay modifications tailored to protect creditor and estate rights, promote judicial economy)