Appalachian Basin Capital LLC

United States Bankruptcy Court, N.D. Ohio·Decided August 30, 2022·No. 22-60052·Unknown

Opinion

The court incorporates by reference in this paragraph and adopts as the findings and orders of this court the document set forth below. This document was signed electronically at the time and date indicated, which may be materially different from its entry on the record.

2 | | 2 ee Lh. a, ay ‘5 Russ Kendig eer United States Bankruptcy Judge Dated: 01:21 PM August 30, 2022

UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

IN RE: ) CHAPTER 11 ) APPALACHIAN BASIN CAPITAL ) CASE NO. 22-60052 LLC, ) ) JUDGE RUSS KENDIG Debtor. ) ) MEMORANDUM OF OPINION ) (NOT FOR PUBLICATION)

Before the court are a motion to strike filed by Debtor and a motion for relief from stay filed by Loretta Beule. The court held a telephonic hearing on August 9, 2022. Anthony DeGirolamo appeared on behalf of Debtor and Anne Silagy appeared on behalf of Loretta Beule. Colette Gibbons, subchapter V trustee, and Todd Bundy and Chrysanthe Vassiles, attorneys for Consumer National Bank, also participated. Following the hearing, the court took the motions under advisement. The following constitutes the court’s findings of fact and conclusions of law under Bankruptcy Rule 7052. It incorporates by reference the findings of fact and conclusions of law contained in its opinion dated June 9, 2022. The court has jurisdiction of this proceeding under 28 U.S.C. § 1334(b) and the general order of reference entered by the United States District Court on April 4, 2012. This is a statutorily core proceeding under 28 U.S.C. § 157(b)(2)(A) and (B). Pursuant to 11 U.S.C. § 1409, venue in this court is proper. This opinion is not intended for publication or citation. The availability of this opinion, in electronic or printed form, is not the result of a direct submission by the court.

BACKGROUND

Debtor owns commercial real estate in Canton, Ohio. David Beule owns 100% of Debtor. His wife, Loretta Beule, is divorcing him. She has filed several pleadings in this case, including a motion to dismiss which Debtor wants stricken. She also filed a motion for relief from stay because she wants to proceed with the divorce case in state court and the domestic relations court is unwilling to proceed against Debtor without an order.

Previously, the court rejected Ms. Beule’s claim to an equitable interest in Debtor because there had been no division of property by the domestic relations court. Without a division awarding her an equitable interest, or finding Debtor to be marital property, this court found her interest to be too speculative to provide a foundation for a claim or participation as a creditor in the case. Debtor argues this finding also means she is not an “interested party” and cannot maintain her motion to dismiss.

DISCUSSION

I. Loretta Beule is a party in interest under 11 U.S.C. § 1112(b)(1).

Under 11 U.S.C. § 1112(b), a “party in interest” may seek dismissal of a chapter 11 case. The question presented is whether Loretta Beule, the divorcing wife of Debtor’s owner with no present interest in or claim against Debtor, is a “party in interest?” Although used in multiple places in the Bankruptcy Code, the term “party in interest” is not defined. The Sixth Circuit endorsed a fluid understanding of the term:

Absent a precise or universal definition, the meaning of “party in interest” depends on the context in which it is used. See, e.g., Jahn v. Burke (In re Burke), 863 F.3d 521, 526 (6th Cir. 2017) (citing In re Morton, 298 B.R. 301, 307 (6th Cir. BAP 2003)); In re Rice, 462 B.R. 651, 656 (6th Cir. BAP 2011). The definition endorsed in In re Morton describes the term “party in interest” as “an expan- dable concept depending on the particular factual context in which it is applied,” such as a party that “has an actual pecuniary interest,” one “who has a practical stake in the outcome,” or “those who will be impacted in any significant way” by the matter. 298 B.R. at 307 (quoting In re Cowan, 235 B.R. 912 (Bankr. W.D. Mo. 1999) (citations omitted)).

Zipkin Whiting Co., LPA v. Barr (In re Felix), 825 Fed.App’x 365, 367 (6th Cir. 2020) (unreported).

The flexible definition of party in interest is adroitly illustrated in In re Player Wire Wheels, Ltd., 421 B.R. 851 (Bankr. N.D. Ohio 2010). In that case, Mrs. Starr was the ex-wife of the deceased owner of Debtor. Pre-bankruptcy, she was given a lien against his membership 2 interests in Debtor to secure their divorce settlement. The interests were released back to her ex- husband as he paid her. When her ex-husband’s estate filed bankruptcy for Debtor, she held a lien on 40-60% of the membership interests. Her attempts to participate in the case were met with mixed success. She was able to be heard during the confirmation process as a party in interest but was not able to vote on the plan because she did not have a direct claim against Debtor or hold an actual equity interest in Debtor. The party in interest requires a review of the particularized facts of the context of the case. Id. at 855. Even though the court previously found that Loretta Beule was not a creditor or an equity interest holder of Debtor, and rejected her claim and right to vote, it does not foreclose a finding she is a party in interest for other purposes.

Ms. Beule wants to press a motion to dismiss. In § 1112(b), the court is instructed to dismiss or convert a case, “whichever is in the best interests of creditors and the estate, for cause . . .” 11 U.S.C. § 1112(b)(1). Section 1112(b)(4) provides a non-exclusive of factors that constitute cause. 11 U.S.C. § 1112(b)(4). Very generally, the examples of cause can be categorized as debtor actions that harm the estate or creditors, debtor behavior that denigrates the bankruptcy system, or a debtor’s inability to confirm/comply with a plan. To be deemed a party in interest, Ms. Beule must have an interest that advances a purpose of § 1112(b). Accord, Cowan, 235 B.R. at 915 (allowing participation that “advances the goals of the Bankruptcy Code, including the equitable distribution of debtors’ assets and the clarification of the rights and obligations of debtors and creditors.”)

Ms. Beule asserts David Beule authorized Debtor’s bankruptcy filing in bad faith. Her main concern is that David Beule will take actions that undervalue Debtor, which she contends is marital property, resulting in a reduced award for her in the divorce proceeding. Debtor counters that she does not have a requisite interest in Debtor and her relief rests with the domestic relations court. The court is persuaded by Ms. Beule. Her relief in the domestic relations court relies on an equitable distribution of Debtor’s assets for fair value in this case.

The court previously recognized that Ms. Beule had a “potential or speculative” interest in Debtor. Abstract interests can qualify a person or entity as a party in interest. For example, in In re Guikema, the provider of investment vehicles for debtor’s 403(b) plan wanted to join debtor’s effort to declare her annuity was not property of the estate. Rhiel v. Ohio Health Corp. (In re Guikema), 363 B.R.

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Related

Rhiel v. Ohio Health Corp. (In Re Guikema)
363 B.R. 853 (S.D. Ohio, 2007)
In Re Johns-Manville Corp.
36 B.R. 743 (S.D. New York, 1984)
Hohenberg v. Hohenberg (In Re Hohenberg)
143 B.R. 480 (W.D. Tennessee, 1992)
In Re Cowan
235 B.R. 912 (W.D. Missouri, 1999)
In Re Player Wire Wheels, Ltd.
421 B.R. 851 (N.D. Ohio, 2009)
Morton v. Morton (In Re Morton)
2003 FED App. 0003P (Sixth Circuit, 2003)
Richard Jahn v. Philip Craig Burke
863 F.3d 521 (Sixth Circuit, 2017)
In re Rice
462 B.R. 651 (Sixth Circuit, 2011)