In Re: U Lock Inc v.

CourtCourt of Appeals for the Third Circuit
DecidedJanuary 27, 2025
Docket24-1163
StatusUnpublished

This text of In Re: U Lock Inc v. (In Re: U Lock Inc v.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: U Lock Inc v., (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 24-1163 ___________

In re: U LOCK, INC., Debtor

GEORGE SNYDER, Appellant ____________________________________

On Appeal from the United States District Court for the Western District of Pennsylvania (W.D. Pa. Civ. No. 2:23-cv-00691) District Judge: Honorable Cathy Bissoon ____________________________________

Submitted Pursuant to Third Circuit LAR 34.1(a) January 23, 2025 Before: KRAUSE, PHIPPS, and ROTH, Circuit Judges

(Opinion filed January 27, 2025) ___________

OPINION* ___________

PER CURIAM

This appeal is one of several stemming from bankruptcy proceedings concerning

debtor U Lock, Inc.

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. George Snyder, Christine Biros, and others formed U Lock to pursue a real estate

development opportunity. To that end, Biros lent U Lock $325,000 to purchase

commercial property on Route 30 in North Huntingdon Township, Pennsylvania.

The property was not developed as envisioned. U Lock instead purported to

operate a storage facility on the property.

It appears that U Lock never filed tax returns, or executed written leases with its

storage tenants, or generated much revenue. According to Snyder, U Lock had no salaried

employees, and though it paid its contractors amounts less than the threshold for filing

IRS Form 1099s, records of those payments have disappeared.1

Because, moreover, U Lock failed to repay Biros on the loan, she took the

company to court. A bench trial in the Westmoreland County Court of Common Pleas

resulted in the imposition of a constructive trust on the subject property and a transfer of

ownership to Biros. U Lock appealed without success. See Biros v. U Lock Inc., 255

A.3d 489 (Pa. Super. Ct. 2021), allocatur denied 271 A.3d 875 (table) (Pa. 2022).

Not long after, Snyder’s sister, Shanni Snyder, forced U Lock into bankruptcy by

filing an involuntary Chapter 7 petition, pursuant to 11 U.S.C. § 303(b)(2). In initial

filings in the Bankruptcy Court, Shanni listed herself as the sole creditor, based on a

default judgment she had obtained against U Lock in an action under the Fair Labor

Standards Act (FLSA), 29 U.S.C. §§ 201 et seq. Shanni valued her claim at $375,100.

1 All references to “Snyder” in this opinion are to the appellant, George Snyder.

2 U Lock did not respond to the petition. The Bankruptcy Court entered an order

designating Snyder and his brother Kash Snyder as principals of U Lock. Creditor

schedules were filed by U Lock’s counsel, and none listed Snyder.

Thereafter, Snyder, who was U Lock’s majority shareholder, filed a claim against

the estate for $99,000, the basis for which he fully described at the time as follows:

“wage, fair labor standards.” App’x Vol. II at 72. At no point did Snyder ever formally

amend his claim.

Biros objected to Snyder’s claim on multiple grounds, including that the claim was

deficient in description and defective under the FLSA.2 In response, Snyder explained

that he filed his claim after researching “Shanni Snyder[’s] claims and how vast and

broad the FLSA was,” and argued that the FLSA “covers me even though I was an officer

and owner” because “I did a lot of work.” App’x Vol. II at 575. Snyder appended a

declaration that included a back-of-the-envelope calculation of his unpaid wages, were he

considered an employee of U Lock. That calculation was not consistent with Snyder’s

original claim.

At a hearing on Biros’s objection (and on various other matters), the Bankruptcy

Court summarized the parties’ arguments and asked Snyder if there was anything else he

2 A bankruptcy case is “an aggregation of individual controversies,” 1 Collier on Bankruptcy ¶ 5.08[1][b], p. 5–43 (16th ed. 2019), including “core proceedings” defined by statute, see 28 U.S.C. § 157(b). An objection, like Biros’s, to a claim made against the bankruptcy estate is an example of a “core” proceeding that the Bankruptcy Court has statutory jurisdiction to adjudicate under § 157(a). See 28 U.S.C. § 157(b)(2)(B).

3 wished the court to consider. Snyder replied under oath that the only thing he would add

is that the bankruptcy trustee “and I were talking about amending the schedules, so I

could have amended that part as well.” App’x Vol. II at 586.

The Bankruptcy Court entered an order sustaining Biros’s objection. In setting

forth its reasoning during the hearing, the Bankruptcy Court first observed that Snyder’s

claim was “just a bare bones claim. It does not have any supporting documentation

substantiating the amounts claimed, or breakdown of the time periods, or the time frames

by which the wages were accrued, and so under [In re Allegheny Int’l, Inc., 954 F.2d 167

(3d Cir. 1992)], I find that it’s not entitled to prima facie validity.” App’x Vol. II at 587.

The Bankruptcy Court added that Snyder did not have a viable claim for unpaid wages

under § 206 of the FLSA, either because the statute exempts “mom-and-pop”

establishments (like U Lock) from coverage, see 29 U.S.C. § 203(s)(2); see also Velez v.

Sanchez, 693 F.3d 308, 327 (2d Cir. 2012), or because the claim was time-barred, see 29

U.S.C. § 255(a).

The Bankruptcy Court also observed that Snyder’s claim might not have been for

unpaid wages at all, but instead for “lost sweat equity or capital contributions that were

provided through his labor and efforts” (which are not recoupable under the FLSA).

App’x Vol. II at 588. Finally, the Bankruptcy Court found compelling the fact that

Snyder’s claim “conflict[s] with sworn statements [regarding U Lock’s workforce] that

were given elsewhere in this case, particularly with respect to the schedules and

4 testimony at the [meeting of creditors under § 341 of the Bankruptcy Code] and in other

sworn declarations.” App’x Vol. II at 588-89.

Snyder appealed to the District Court pro se and argued that the Bankruptcy Court

misapplied the FLSA and should have held an evidentiary hearing. The District Court

rejected those arguments and affirmed the Bankruptcy Court’s order.3 Still proceeding

pro se, Snyder has now appealed to this Court.4

Having reviewed the record and Snyder’s arguments on appeal, we determine that

Snyder has presented no valid basis on which to disturb the judgment of the District

Court.5 In particular, while Snyder contends that he was entitled to a full evidentiary

3 The District Court had appellate jurisdiction under 28 U.S.C. §§ 158(a)(1) and 1334.

4 We have jurisdiction under 28 U.S.C.

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Related

Arbaugh v. Y & H Corp.
546 U.S. 500 (Supreme Court, 2006)
Adams v. Zarnel
619 F.3d 156 (Second Circuit, 2010)
Velez v. Sanchez
693 F.3d 308 (Second Circuit, 2012)
Daryoush Taha v. County of Bucks
862 F.3d 292 (Third Circuit, 2017)
Biros, C. v. U Lock
2021 Pa. Super. 104 (Superior Court of Pennsylvania, 2021)

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