Chavez-DeRemer v. Arsenal Health, LLC

CourtDistrict Court, M.D. Alabama
DecidedSeptember 19, 2025
Docket2:24-cv-00434
StatusUnknown

This text of Chavez-DeRemer v. Arsenal Health, LLC (Chavez-DeRemer v. Arsenal Health, LLC) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chavez-DeRemer v. Arsenal Health, LLC, (M.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

LORI CHAVEZ-DEREMER,1 ) Secretary of Labor, ) United States Department of Labor, ) ) Plaintiff, ) ) v. ) CIVIL CASE NO. 2:24-cv-434-ECM ) [WO] ARSENAL HEALTH, LLC, et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER I. INTRODUCTION This case concerns an Employee Retirement Income Security Act of 1974 (“ERISA”) action brought on July 23, 2024, by the Secretary of Labor (“the Plaintiff”) against Defendants Arsenal Health, LLC and Arsenal Insurance Management, Inc. (collectively, “the Defendants”). The Plaintiff alleges that the Defendants imprudently managed a non-plan Multi- Employer Welfare Arrangement (“MEWA”) covered by ERISA and became insolvent. (Doc. 1 at 1–2, paras. 2, 7–9). She further alleges that the Defendants filed for Chapter 11 bankruptcy and ceased operations but failed to terminate the non-plan MEWA to ensure that funds held were distributed to pay outstanding medical claims. (Id. at 2 paras. 8–9).

1 Lori Chavez-DeRemer is now the Secretary of Labor, United States Department of Labor, and is automatically substituted as a party under Federal Rule of Civil Procedure 25(d). Accordingly, the Clerk of the Court is directed to correct the docket to reflect this change. The Plaintiff represents that from those bankruptcy proceedings, she was able to recover around $570,000 for payment of unpaid claims. (Id. at 3, para. 9).

In the present action, the Plaintiff pursues an injunction to prevent Defendants from engaging in further actions that violate ERISA and the appointment of an independent fiduciary at the Defendants’ expense for the distribution of assets recovered. (Id. at 3–4). This case sat dormant for over three months until William Homony, nonparty and trustee of Arsenal Liquidating Trust (“ALT”), filed a waiver of service on November 4, 2024. (Doc. 6 at 1).

On November 13, 2024, the Plaintiff filed an “unopposed” motion for the appointment of a receiver (“Motion to Appoint a Receiver”) to hold in trust and administer funds previously managed by the Defendants. (Doc. 7). An examination of the record reveals that the Defendants (1) are bankrupt entities; (2) are unrepresented by counsel; (3) have not been served; and (4) have not answered or otherwise responded. After careful

review, and for the reasons explained further below, the Court finds that the motion is due to be denied without prejudice. II. DISCUSSION A. Authority In her Motion to Appoint a Receiver, the Plaintiff cites 29 U.S.C. § 1109(a) for this

Court’s appointment authority. (Doc. 7 at 4, para. 10). Section 1109(a) reads: Any person who is a fiduciary with respect to a plan who breaches any of the responsibilities, obligations, or duties imposed upon fiduciaries by this subchapter shall be personally liable to make good to such plan any losses to the plan resulting from each such breach, and to restore to such plan any profits of such fiduciary which have been made through use of assets of the plan by the fiduciary, and shall be subject to such other equitable or remedial relief as the court may deem appropriate, including removal of such fiduciary. A fiduciary may also be removed for a violation of section 1111 of this title.

This provision is silent as to the appointment of a receiver, and the Plaintiff does not explain how § 1109(a) confers appointment authority, or why the appointment of a receiver—a remedy not expressly listed—is the appropriate equitable remedy under § 1109(a). The Plaintiff fails to provide any additional authority in support of her Motion to Appoint a Receiver. Moreover, the Plaintiff has not explained why an appointment is proper here, considering the Defendants have not appeared. Further, the Plaintiff has not identified any criteria for the Court to evaluate whether Receivership Management, Inc. (“RMI”), the Plaintiff’s proposed fiduciary, is appropriate to serve. (Doc. 7).2 Further, the Court questions whether the motion can be fairly characterized as unopposed, as the Defendants have not appeared. B. Copies of Specific Bankruptcy Records Although the Plaintiff references the Defendants’ bankruptcy records, she fails to state with specificity which documents would aid the Court’s decision to appoint a

2 The Plaintiff provided some information about RMI’s proposed receiver conduct (doc. 7-2 at 1) and some benefits of the proposal along with the estimated amount of costs and fees (id. at 2). However, without more, the Court cannot evaluate whether RMI’s appointment is appropriate. particular receiver and whether the bankruptcy document records constitute binding or persuasive authority.3 (See, e.g., doc. 1 at 2, para. 8; doc. 7 at 2–3, paras. 4, 6).

Relevant here, the bankruptcy plan (partially quoted in the Plaintiff’s Motion to Appoint a Receiver (doc. 7 at 3, para. 8))4 reads: As will be more fully set forth in the Liquidating Trust Agreement, the Plan contemplates that the Department of Labor, with the assistance of the Liquidating Trustee, to the extent reasonably requested, shall bring an action in a federal district court of competent jurisdiction to appoint an independent fiduciary for the Health Benefit Plans. The Independent Fiduciary will have the responsibility, among others, for distributing the Customer Trust Funds and any other funds transferred from the Health Care Fiduciary Account[.]

(Doc. 292 at 32 in In re Arsenal Intermediate Holdings, Case No. 23-10097 (CTG) (Bankr. D. Del.) (emphases added)). The Plaintiff does not explain the current status or content of the Liquidating Trust Agreement (“LTA”). The content of the LTA is important because the bankruptcy plan contemplates the LTA adding specificity to the process by which an action to enforce the plan should be brought. Further, the Plaintiff does not address whether ALT is assisting in the action as set forth in the plan, an issue addressed more fully below.

3 The Court acknowledges that a confirmed Chapter 11 bankruptcy plan binds the debtors (11 U.S.C. § 1327(a))—Arsenal Intermediate Holdings, LLC, and the Defendants. (Doc. 292 at 1 n.1 in In re Arsenal Intermediate Holdings, Case No. 23-10097 (CTG) (Bankr. D. Del.)).

4 The Plaintiff’s selected portion reads: “The Plan further provides that [the] Plaintiff ‘shall bring an action in a federal district court of competent jurisdiction to appoint an independent fiduciary for the Health Benefit Plans. The Independent Fiduciary will have the responsibility, among others, for distributing the Customer Trust Funds and any other funds transferred from the Health Care Fiduciary Account.’” (Doc. 7 at 3, para. 8). The Plaintiff omitted two key facts: (1) The plan contemplates the Liquidating Trust Agreement will more fully set forth how this litigation should be brought, and (2) the Liquidating Trustee appears to be a cooperative rather than adversarial party based on the bankruptcy plan. C. ALT’s Role as Liquidating Trust in this Action Attorney Alan M. Root (“Attorney Root”) represents “Arsenal Liquidating Trust.”

(Doc. 12 at 1, para. 2). The Plaintiff states ALT is required by the bankruptcy plan to hold and turnover customer trust funds and any other funds in the health care fiduciary accounts. (Doc. 7 at 3–4, paras. 8–9). However, the Plaintiff does not clearly describe the legal relationship of ALT to the Defendants—e.g., whether ALT can stand in for the Defendants—beyond its role as the Liquidating Trust. This adds to the Court’s difficulty in discerning whether appointment is proper.

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Bluebook (online)
Chavez-DeRemer v. Arsenal Health, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chavez-deremer-v-arsenal-health-llc-almd-2025.