The Roman Catholic Diocese of Syracuse, New York, 665 B.R. 942

The Roman Catholic Diocese of Syracuse filed for Chapter 11 bankruptcy; an order (the "Bar Date Order") set rules for handling confidential survivor proof of claim information.
AZRA, an insurance company, signed the required Confidentiality Agreement and became an Authorized Party permitted to access survivor claims.
AZRA inadvertently disclosed confidential survivor information to Insurance Services Office, Inc. (ISO), a non-Authorized Party, via its ClaimSearch Platform for fraud detection.
AZRA discovered the breach in May 2023 but did not notify the Court and Committee until September 2023 (a 149-day delay) via a "Disclosure Letter."
The Official Committee of Unsecured Creditors sought a contempt finding and notification to affected survivors; AZRA stopped the unauthorized disclosure and paid over $100,000 in legal fees for the Committee’s investigation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there a clear and unambiguous violation of the Bar Date Order?	Yes; unauthorized disclosure to ISO was a clear violation.	No; any violation was technical and inadvertent; Bar Date Order unclear.	Violation was clear and unambiguous; contempt appropriate.
Was the delay in notification a further breach?	Yes; 149 days is not "prompt," breaching the Confidentiality Agreement.	Delay was due to investigating the scope of breach; not unreasonable.	Delay was an additional breach; breach should be reported promptly.
Is bad faith required to find civil contempt?	No; objective standard applies (no fair ground of doubt required).	Yes; lack of intent and no bad faith means no contempt should be found.	Bad faith not required; objective standard applies.
Should sanctions/coercive orders be imposed?	Compensatory sanctions for costs incurred; survivors should be notified.	No further relief as violation stopped, no ongoing noncompliance.	No additional sanctions; notification of survivors allowed.

Taggart v. Lorenzen, 587 U.S. 554 (civil contempt appropriate under objective standard for bankruptcy order violations)
King v. Allied Vision, Ltd., 65 F.3d 1051 (clear and convincing evidence required for contempt finding)
Worms v. Rozhkov (In re Markus), 78 F.4th 554 (elements for civil contempt in bankruptcy cases)
Bruce v. Citigroup Inc., 75 F.4th 297 (reaffirming bankruptcy court’s authority for civil contempt)
Citibank, N.A. v. Brigade Capital Mgmt., LP, 49 F.4th 42 (prompt notice required for compliance under court orders)