Harrington v. Dornier Aviation (North America), Inc. Ex Rel. DANA Liquidating Trust (In Re Dornier Aviation (North America), Inc.)

305 B.R. 650, 2004 U.S. Dist. LEXIS 1453, 42 Bankr. Ct. Dec. (CRR) 145, 2004 WL 231397
CourtDistrict Court, E.D. Virginia
DecidedFebruary 3, 2004
DocketCiv.A. 03-1274-A
StatusPublished
Cited by5 cases

This text of 305 B.R. 650 (Harrington v. Dornier Aviation (North America), Inc. Ex Rel. DANA Liquidating Trust (In Re Dornier Aviation (North America), Inc.)) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harrington v. Dornier Aviation (North America), Inc. Ex Rel. DANA Liquidating Trust (In Re Dornier Aviation (North America), Inc.), 305 B.R. 650, 2004 U.S. Dist. LEXIS 1453, 42 Bankr. Ct. Dec. (CRR) 145, 2004 WL 231397 (E.D. Va. 2004).

Opinion

MEMORANDUM OPINION

ELLIS, District Judge.

At issue in these consolidated bankruptcy appeals is whether 11 U.S.C. § 502(b)(7) of the Bankruptcy Code operates to limit appellants’ claims against the bankrupt estate for damages resulting from the failure of the bankrupt, appellants’ employer, to provide appellants with ninety days notice prior to termination as required by the terms of their employment agreements.

I.

Appellee Dornier Aviation (North America), Inc. (“DANA”) is a supplier of aircraft maintenance and repair services and parts and an affiliated company of Fairchild Dornier Corporation (“Fairchild”), a Delaware corporation. On April 24, 2002, several alleged creditors filed an involuntary Chapter 7 petition against DANA. Because DANA did not object to the petition, the bankruptcy court in this district entered an Order for Relief and an order converting the case to Chapter 11 on May 20, 2002. After the debtor’s attempted reorganization proved unsuccessful, the bankruptcy court entered an order on February 14, 2003 confirming DANA’s liquidation plan. Thereafter, pursuant to the liquidation plan and the bankruptcy court’s order, all of DANA’s assets were transferred on February 25, 2003 to a new entity, DANA Liquidating Trust (“DLT”). DLT is the entity charged with administering the assets of the estate and pursuing objections to any future claims filed in the bankruptcy case.

Appellants Harrington and Wolf were high level executive employees of DANA. Both were hired in October 2000, Harrington as the President and Chief Executive Officer at a base salary of $750,000 per year and Wolf as the Chief Operating Officer at a base salary of $400,000 per year. Pursuant to their employment agreements, both executives, in addition to their base salaries, were also entitled to annual incentive bonus compensation, company stock, life, health, and disability insurance, tax preparation and financial planning services, country club or fitness club memberships, four weeks annual vacation, as well as other benefits. Of note here is that the executives’ employment agreements (i) provided that the executives were entitled to two years severance pay in the event they were terminated by the company without cause 1 and (ii) required that the company either provide ninety days notice prior to termination without cause, or alternatively, pay the executive his base salary for ninety days post termination. 2 *652 Both executives were terminated in 2002— Harrington in early April and Wolf in late June. Neither party disputes that appellants were terminated without cause and without ninety days prior notice.

Both appellants asserted claims for damages stemming from their termination and accordingly filed proofs of these claims against DLT on September 12, 2002. Harrington’s claim (No. 122) is for $1,359,972 and Wolfs claim (No. 129) is for $990,480. 3 On May 7, 2003, DLT objected to the claims on various grounds, including 11 U.S.C. § 502(b)(7), which DLT argues limits appellants’ allowed claims to the compensation the executive would have received during the year after his termination. The parties thereafter engaged in negotiations that resulted in the resolution of many issues raised in DLT’s objections, including limiting appellants’ claims for two years severance pay to one year. 4 Nonetheless, the parties were unable to resolve whether appellants’ were entitled to an additional ninety days base salary as a consequence of DANA’s failure to provide ninety days notice prior to termination (“notice compensation”) or instead, whether this claim was also limited by § 502(b)(7).

The bankruptcy court then held a hearing on DLT’s objection to appellants’ claims on August 25, 2003 in the course of which it heard argument but no testimonial evidence. 5 During this hearing, the bankruptcy court ruled that appellants’ claims for notice compensation were limited by § 502(b)(7). More specifically, the bankruptcy court found that the requirement that DANA provide ninety days notice prior to termination “in effect [ensured that] if [the employees] are not given notice, they get an additional three months of severance,” and that this compensation, like the two year severance pay, was limited by § 502(b)(7). As a consequence, the bankruptcy court entered an order that partially allowed both claims. The bankruptcy court allowed Harrington’s claim in the amount of $793,561 and Wolfs claim in the amount of $430,204; $4650 of each claim was allowed as a priority claim, while the remainder was a general unsecured claim. As a condition to partial allowance of the claims, the bankruptcy court required Harrington and Wolf to execute a general release of all claims against DLT.

Wolf and Harrington each filed a timely *653 Notice of Appeal. 6 The appellants then filed a joint motion requesting consolidation of their appeals, which motion was granted. 7 Appellants’ argue that their claims for notice compensation are not limited by § 502(b)(7) and thus seek reversal of the bankruptcy court’s order, or in the alternative, a remand to the bankruptcy court for further proceedings. Both Harrington and Wolf argue that their claims for ninety days notice compensation should be allowed in full; in this respect, Harrington seeks $184,931 and Wolf seeks $98,630.

II.

A district court’s scope of review of a bankruptcy court’s order is well-established. Whereas a bankruptcy court’s findings of fact are reviewed only for clear error, its conclusions of law are subject to de novo review. See In re Southeast Hotel Prop., L.P., 99 F.3d 151, 154 (4th Cir. 1996); In re Johnson, 960 F.2d 396, 399 (4th Cir.1992). Mixed questions of law and fact are also reviewed de novo. See In re Litton, 330 F.3d 636, 642 (4th Cir.2003). In this instance, the bankruptcy court’s factual findings are not in dispute. Thus, at issue and subject to de novo review here is the bankruptcy court’s holding that appellants’ claims for ninety days base salary are limited by § 502(b)(7) because DANA failed to provide ninety days notice prior to termination.

III.

Section 502(b)(7) of the Bankruptcy Code 8 is the means by which Congress seeks to protect bankrupt estates from large, sometimes exorbitant claims by employees for damages “resulting from the termination of an employment contract.” 9

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305 B.R. 650, 2004 U.S. Dist. LEXIS 1453, 42 Bankr. Ct. Dec. (CRR) 145, 2004 WL 231397, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harrington-v-dornier-aviation-north-america-inc-ex-rel-dana-vaed-2004.