AP Framing, Inc.

CourtUnited States Bankruptcy Court, N.D. Georgia
DecidedApril 25, 2025
Docket20-68856
StatusUnknown

This text of AP Framing, Inc. (AP Framing, Inc.) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AP Framing, Inc., (Ga. 2025).

Opinion

ae c a" Oe” of (i NB

Sa Eo, = BM i nf Siar ae IT IS ORDERED as set forth below:

Date: April 25, 2025 “i Jeffery W. Cavender U.S. Bankruptcy Court Judge

UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

IN RE: CASE NO. 20-68856-JWC AP FRAMING, INC., CHAPTER 11 Debtor.

ORDER The Bankruptcy Code designs a sequence of protections to prevent creditors from commencing or continuing litigation against a debtor. Initially, the automatic stay under 11 U.S.C. § 362(a)(1) prevents “the commencement or continuation, ... of a judicial, administrative, or other action or proceeding against the debtor that was or could have been commenced before the commencement” of the case. If a debtor receives a discharge, the automatic stay gives way to 11 U.S.C. § 524(a)(2), which “operates as an injunction against the commencement or continuation of an action,

the employment of process, or an act, to collect, recover or offset any such debt as a personal liability of the debtor.” Where, as in this case, a debtor under subchapter V of chapter 11 confirms a non-consensual plan under 11 U.S.C. § 1191(b), such debtor

is protected from the commencement or continuation of litigation by whatever language is included in the plan that protects the debtor until payments under the plan are completed and a discharge is received. In this case that provision is a plan injunction. Unlike §§ 362 and 524, however, no provision in the Bankruptcy Code governs the appropriate breadth of a plan injunction or how to modify it. The Court is confronted by this statutory negative space and must determine whether it is

proper to reopen the Debtor’s case to allow a creditor to proceed in a state court suit nominally against the Debtor for purposes of pursuing the Debtor’s insurers. Secondarily, if reopening is appropriate, the Court must assess whether it is necessary, and if necessary, how, to modify the plan injunction to allow the litigation to proceed. For the reasons explained below, the Court finds it appropriate to reopen the bankruptcy case to prevent prejudice to a creditor seeking to pursue litigation

nominally against the Debtor given that neither the Debtor nor other creditors will be prejudiced. Despite some question as to the necessity of modification, the Court also finds that modification is appropriate as the Debtor is a necessary party to the litigation, the Court lacks evidence indicating the Debtor will bear material litigation expenses, and, in any event, the creditor seeking relief to collect against insurance

2 cannot collect against the Debtor personally or from its assets. Background This matter is before the Court on Balfour Beatty Construction, LLC’s

(“Balfour Beatty”) Motion to Reopen and Lift Stay (Doc. No. 206) (the “Motion to Reopen”). Balfour Betty seeks the reopening of the bankruptcy case of AP Framing, Inc. (the “Debtor”) and modification of the Debtor’s chapter 11 subchapter V plan injunction to continue litigation in Tennessee state court. The Debtor filed a Response in Opposition (Doc. No. 209) (the “Response”), and the Court held a hearing on the Motion to Reopen on February 20, 2025, at which counsel for the Debtor, counsel for

Balfour Beatty, and the now-terminated subchapter V trustee appeared. The Court took this matter under advisement at the hearing’s conclusion. The Debtor commenced this case under subchapter V of chapter 11 on August 10, 2020. The Debtor filed its first Chapter 11 Small Business Subchapter V Plan on November 6, 2020 (Doc. No. 73), a First Amended Plan on December 4, 2020 (Doc. No. 83), and a Second Amended Plan on January 5, 2021 (Doc. No. 114) (the “Plan”). Prior to confirmation of the Plan, Balfour Beatty filed a Motion to Deem Late-Filed

Proof of Claim Timely (Doc. No. 123) stating it had not received notice of the Debtor’s bankruptcy case and seeking relief from the Court to allow a late-filed proof of claim. The Court granted Balfour Beatty’s motion and deemed its late-filed and unliquidated claim timely by order entered on January 27, 2021 (Doc. No. 131). The Plan was confirmed by an order entered on February 10, 2021 (Doc. No. 142) (the

3 “Confirmation Order”). Because the Debtor confirmed a non-consensual plan under 11 U.S.C. § 1191(b), the Debtor is not entitled to a discharge until payments are completed under the Plan. Pending completion of Plan payments, however, the Plan

includes an injunction preventing the continuation or commencement of actions against the Debtor during the term of the Plan. On March 26, 2022, after confirmation of the Debtor’s Plan, Balfour Beatty filed a motion requesting relief from the automatic stay to seek recovery from the Debtor’s insurance (Doc. No. 192). Five days later, a consent order was entered modifying the stay to permit Balfour Beatty “to continue with the ongoing Civil

Litigation for purposes of liquidating damages, to collect against Debtor’s insurance carrier only to the extent of available insurance and not against Debtor.” (Doc. No. 193) (the “Consent Order”).1 A little over one month after entry of the Consent Order, the Debtor’s bankruptcy case was closed. The Debtor’s Plan provides for yearly payments to unsecured creditors over a five-year period, and payments under the Plan are almost complete. One final installment is due in April of 2026. (See Doc. No. 73, p. 16; Doc. No. 209, ¶ 32).

Balfour Beatty as the holder of an unliquidated claim has received no distributions under the Debtor’s Plan, the Plan makes no provision for reserves for unliquidated claims, and Balfour Beatty is not seeking to liquidate its claims for

1 The motion and related Consent Order requested and authorized relief from the automatic stay but are more appropriately viewed as seeking and obtaining a consensual modification of the Plan injunction to allow the litigation to continue. 4 purposes of obtaining a distribution under the Debtor’s Plan. Instead, Balfour Beatty seeks to reopen this bankruptcy case to continue pursuing litigation nominally against the Debtor to collect from the Debtor’s insurance. Balfour Beatty’s claim

arises from an indemnification agreement related to the construction of the Demonbreun Apartments in Charlotte, North Carolina (Doc. No. 206). The Consent Order permitted Balfour Beatty to continue one action in the Superior Court of Fulton County, Georgia, Case No 20-CVS-016165, and three different actions “to pursue any available insurance only” in the Superior Court of North Carolina, Mecklenburg County: (1) Case No. 20-CVS-010180; (2) Case No. 2020-CV-341255; and (3) and Case

No. 20-CVS-1272 (Doc. No. 193). Sometime in 2022, Case No. 20-CVS-1272 (the “Demonbreun Case”) was dismissed for improper venue (Doc. No. 206, ¶ 10). Balfour Beatty then filed a complaint in the Circuit Court of Davidson County, Tennessee against the Debtor commencing Case Number 22C2081 (Doc. No. 209, Ex. A), raising substantially the same claims asserted in the Demonbreun Case.2 Additionally, in 2023, Balfour Beatty filed an answer and third-party complaint, including claims against the Debtor related to the Demonbreun project, in Case Number 20C2292 in

the Sixth Circuit Court of Davidson County, Tennessee (Doc. No. 209, Ex. B). The litigation in Tennessee proceeded between Balfour Beatty and the Debtor largely without regard to the Plan injunction. Recently, however, issues with respect

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In the Matter of Gladys E. Shondel, Debtor-Appellant
950 F.2d 1301 (Seventh Circuit, 1991)
Hendrix v. Page
986 F.2d 195 (Seventh Circuit, 1993)
Wilkinson v. Vigilant Insurance Company
224 S.E.2d 167 (Supreme Court of Georgia, 1976)
In Re Tarrer
273 B.R. 724 (N.D. Georgia, 2001)
Patronite v. Beeney (In Re Beeney)
142 B.R. 360 (Ninth Circuit, 1992)
In Re Koch
229 B.R. 78 (E.D. New York, 1999)
Granger v. Harris (In Re Harris)
85 B.R. 858 (D. Colorado, 1988)
In Re Phillips
288 B.R. 585 (M.D. Georgia, 2002)
In Re Doar
234 B.R. 203 (N.D. Georgia, 1999)
In Re Catania
94 B.R. 250 (D. Massachusetts, 1989)
Stoneking v. Histed (In Re Stoneking)
222 B.R. 650 (M.D. Florida, 1998)
West v. White (In Re White)
73 B.R. 983 (District of Columbia, 1987)
Apex Oil Co. v. Sparks (In Re Apex Oil Co.)
406 F.3d 538 (Eighth Circuit, 2005)
In re Hayden
477 B.R. 260 (N.D. Georgia, 2012)
In re Podmostka
527 B.R. 51 (D. Massachusetts, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
AP Framing, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ap-framing-inc-ganb-2025.