J.D. v. Houser

CourtDistrict Court, D. Delaware
DecidedMarch 25, 2025
Docket1:24-cv-00213
StatusUnknown

This text of J.D. v. Houser (J.D. v. Houser) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.D. v. Houser, (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE IN RE: : Chapter 11 BOY SCOUTS OF AMERICA and : Case No. 20-10343-LSS DELAWARE BSA LLC, : (Jointly Administered) Debtors. : J.D., et al., : Civ. No. 24-213-RGA : (lead) Appellants, : Civ. No. 24-265-RGA : Civ. No. 24-287-RGA : (consolidated) The Honorable Barbara J. Houser (Ret.), in her capacity —: as Trustee of the BSA Settlement Trust, Appellee.

OPINION

Katherine L. Hemming, Campbell & Levine, LLC, Wilmington, DE; Joel M. Walker, NYE, Stirling, Hale, Miller, & Sweet LLP, Pittsburgh, PA, attorneys for appellant J.D. Charles J. Brown, HI, Gellert Seitz Busenkell & Brown LLC, Wilmington, DE; Tyler H. Fox, Gellert Seitz Busenkell & Brown LLC, Cambridge, MA, attorneys for appellant D.S. David T. Crumplar, Jacobs & Crumplar, P.A., New Castle, DE; Jennifer Bogan, Babin Law, LLC, Columbus, OH, attorneys for appellants J.H. and K.S. Kami E. Quinn, Emily P. Grim, Michael B. Rush, Chelsea A. Zrzaczek, Gilbert LLP, Washington, DC; Anthony M. Saccullo, Mark T. Hurford, Thomas H. Kovach, Mary E. Augustine, A.M. Saccullo Legal, LLC, Bear, DE, attorneys for appellee the Honorable Barbara J. Houser (Ret.), in her capacity as Trustee of the BSA Settlement Trust

March AS , 2025

woul lal Gelli JUDGE: These appeals arise in the chapter 11 cases of Boy Scouts of America and Delaware BSA LLC (together, the “Debtors”). Appellants are four holders of Direct Abuse Claims, that is, four individuals with claims that they are survivors of abuse suffered as a consequence of participation in scouting. In brief, they each checked a box electing to take an expedited $3500 payout rather than participating in more demanding proceedings that might have led to a much greater payout. They stated, without contradiction, that they did not intend to check that box. In the Bankruptcy Court, they sought to change the elections. The Bankruptcy Court denied their requests. See Bankr. D.I. 11798! (denying motion of J.D.), Bankr. D.I. 11790 (denying motion of D.S.), and Bankr. D.I. 11797 (denying motion of K.S. and J.H.) (together, the “Orders”). The Bankruptcy Court’s principal holding was that the requested relief would modify the confirmed reorganization plan, and Appellants could not request such relief. The appeals were consolidated,” and the merits of the appeals are fully briefed. (D.I. 14, 16, 18, 22, 26, 27, 29.) No party requested oral argument. For the reasons set forth below, the Orders are affirmed. I. BACKGROUND The Bankruptcy Court accurately and clearly described the factual and procedural background for the legal issues it faced, which essentially are renewed on appeal. I do not think I could improve upon the Bankruptcy Court’s description, so I quote it at length (and without its

' The docket of the chapter 11 cases, captioned Jn re Boy Scouts of America, No. 20-10343 (LSS) (Bankr. D. Del.), is cited herein as “Bankr, D.I.__.” The appendix (D.I. 17) filed in support of appellant J.D.’s opening brief is cited herein as “APP__,” and the appendix (D.I. 23) filed in support of the Trustee’s answering brief is cited herein as “Trustee APP__.” * Hereinafter, “D.I.” cites to the docket of the consolidated appeal, Civ. No. 24-213-RGA.

headings and footnotes). The Plan confirmed in the Boy Scouts of America bankruptcy case channeled all abuse claims to a Settlement Trust for liquidation and payment. The Plan and the Trust Distribution Procedures (“TDP”) provide holders of Direct Abuse Claims three options for liquidation and payment: (i) an Expedited Distribution of $3,500, (ii) the Independent Review Option or (ili) the general review process capped by the maximum values in the Claims Matrix. A holder of a Direct Abuse Claim selected the Expedited Distribution option by checking a box on his ballot. The Motions seek relief with respect to the Expedited Distribution option. Each Motion was filed by or on behalf of a holder of a Direct Abuse Claim who checked the box on his respective ballot electing to receive the Expedited Distribution. Based on a variety of legal theories (or sometimes no legal theory at all), each claimant seeks to change/rescind or revoke his respective Expedited Distribution election in order to participate in one of the other two options. Because I have determined that to grant this request would constitute an amendment to the Plan, the Motions must be denied. On September 30, 2021, after a multi-day hearing and numerous amendments to Plan-related documents, the Solicitation Order was entered. The Solicitation Order approved voting and tabulation procedures, forms of ballots and the package of solicitation materials to be mailed to claimants. The solicitation package included the Confirmation Hearing Notice, the Disclosure Statement with all exhibits, the Plan and, where appropriate, a ballot. The Solicitation Order set a voting deadline of December 14, 2021, which was ultimately extended to March 4, 2022 for holders of Abuse Claims. Holders of Direct Abuse Claims were solicited as Class 8 creditors either directly or through their counsel, at the holder's election. Accordingly, two forms of Class 8 ballots were approved—a Ballot for Class 8 (Direct Abuse Claims) and a Class 8 Direct Abuse Claim Master Ballot. The front page of the Ballot for Class 8 (Direct Abuse Claim) (“Ballot”) informed holders that there were four items to be completed on the Ballot: 1. VOTE TO ACCEPT OR REJECT THE PLAN 2. DECIDE WHETHER TO MAKE THE OPTIONAL $3,500 EXPEDITED DISTRIBUTION ELECTION 3. DECIDE WHETHER TO OPT OUT OF THE THIRD PARTY RELEASE 4. SIGN YOUR BALLOT The front page also cautioned claimants to read the instructions carefully before filling out the Ballot. Page 3 of the Ballot is largely devoted to a description of the Expedited Distribution election. The Expedited Distribution election itself appears on page 6 of the Ballot as Item 3:

Item 3. Expedited Distribution Election. Please note that if you make the Expedited Distribution election set forth in Item 3, you must still complete the remaining Items on the Ballot. If the Plan is confirmed as set forth above and in the Plan, the holder of an eligible Direct Abuse Claim ELECTS to: Receive the Expedited Distribution of a one-time Cash payment from the Settlement Trust in the amount of $3,500.00 conditioned upon satisfaction of the criteria set forth in the Trust Distribution Procedures, in exchange for a full and final release in favor of the Settlement Trust, the Protected Parties, and the Chartered Organizations. By signing the Ballot, the claimant acknowledges that he has received a copy of the Disclosure Statement and Plan and that, among other things, he “understands and, if accepting the Plan, agrees with the treatment provided for [his] Claims under the Plan.” The Ballot did not create the classes of claims or the Expedited Distribution option. Rather, the Expedited Distribution election on the Ballot implemented the Plan. The Plan establishes Class 8 as an impaired class and provides that liability for those claims is assumed by the Settlement Trust and “processed, liquidated, and paid in accordance with the terms, provisions, and procedures of the Settlement Trust Documents.” The Plan also provides that holders of Class 8 claims may elect to receive the Expedited Distribution, which is defined in the Plan as “a one-time Cash payment from the Settlement Trust of $3,500.00, conditioned upon satisfaction of the criteria set forth in the Trust Distribution Procedures.” The Plan further provides that the election is made on the Ballot. The Expedited Distribution is detailed in Article VI of the TDP. The TDP provides that the claimant must elect the Expedited Distribution in accordance with the Plan and sets out the criteria and minimal documentation that must be submitted to obtain the $3,500 payment.

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Bluebook (online)
J.D. v. Houser, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jd-v-houser-ded-2025.