Joshua Kalchert v. Cynthia Adamek et al.

CourtDistrict Court, E.D. Michigan
DecidedFebruary 20, 2026
Docket2:24-cv-12637
StatusUnknown

This text of Joshua Kalchert v. Cynthia Adamek et al. (Joshua Kalchert v. Cynthia Adamek et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joshua Kalchert v. Cynthia Adamek et al., (E.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION JOSHUA KALCHERT,

Plaintiff, Case No. 24-12637 Honorable Laurie J. Michelson v.

CYNTHIA ADAMEK et al.,

Defendants.

OPINION AND ORDER GRANTING IN PART AND DENYING IN PART WELLPATH AND WELLPATH INDIVIDUAL DEFENDANTS’ MOTION TO DISMISS [20] Joshua Kalchert arrived at the Oakland County Jail on October 15, 2021, after the Berkley Police Department arrested him for a parole violation. (ECF No. 28, PageID.687.) During booking, Kalchert told jail officials that he wanted medical attention because he had a “swollen left wrist and arm with pain and a limited range of motion.” (Id. at PageID.687–688.) During a medical screening on October 16, Kalchert informed medical officials that he was undergoing withdrawal from drug use, including experiencing seizures. (Id. at PageID.688.) On October 17, Kalchert told medical officials that his wrist and arm were getting worse. (Id.) Later that evening, Kalchert was found unresponsive, experienced a possible seizure, and was transported to a local hospital where he was “diagnosed with sepsis, necrotizing fasciitis, and an abscess in his left arm with pain from his elbow down to his left hand,” which increased his white blood cell count and respirations and required “surgical intervention.” (Id. at PageID.688–689.) Kalchert brought suit under 42 U.S.C. § 1983 against Wellpath, three Oakland County Jail medical officials employed by Wellpath, and Oakland County. (ECF No. 1, PageID.2–5.) On November 15, 2024, Wellpath docketed a Suggestion of

Bankruptcy and Notice of Stay. (ECF No. 9.) This case was then stayed. (ECF No. 13.) Following several months of bankruptcy proceedings, on May 1, 2025, the United States Bankruptcy Court for the Southern District of Texas entered its findings of fact, conclusions of law, and order “(I) Confirming the First Amended Joint Chapter 11 Plan of Reorganization of Wellpath Holdings, Inc. and Certain of its Debtor Affiliates . . . .” (the “Bankruptcy Plan”) (ECF No. 20-3.) The stay in this case was

then lifted. (ECF Nos. 17, 18.) And soon after, Wellpath and the individual defendants filed this motion arguing that Kalchert’s claims were extinguished by the bankruptcy proceedings. (ECF No. 20.) The motion is fully briefed (ECF Nos. 28, 30) and does not require further argument. See E.D. Mich. LR 7.1(f)(2). For the reasons provided below, the motion (ECF No. 20) will be GRANTED IN PART and DENIED IN PART.

Start with Wellpath, which argues that the Bankruptcy Plan forecloses any

claim against it. (ECF No. 20, PageID.180–181) (arguing that “all Claims and Causes of Action against . . . Wellpath, LLC., are discharged and holders of such Claims and Causes of Action are permanently enjoined from, among other things, commencing or continuing any proceeding of any kind, including the instant proceeding . . . .”). Kalchert, on the other hand, maintains that “Wellpath is and remains a necessary party to determine liability and damages as the Bankruptcy Court has ordered,” so “[i]t should not be dismissed.” (ECF No. 28, PageID.695.) The Bankruptcy Code prohibits a creditor from “recover[ing] or offset[ing] any

such debt as a personal liability of the debtor,” 11 U.S.C. § 524(a)(2). But it leaves open the possibility that a debtor may collect from another entity liable for the debt, like an insurer. See id. at § 524(e) (providing that “discharge of a debt of the debtor does not affect the liability of any other entity on, or the property of any other entity for, such debt”). So looking at the Bankruptcy Code alone, Kalchert’s request that Wellpath remain as a nominal defendant so he can seek to collect from an insurer

seems permissible. See, e.g., In re Talley, 656 B.R. 422, 424 (Bankr. E.D. Mich. 2024) (requiring debtor to remain in the suit to determine liability which, if found, the plaintiff would collect from a third party). But the Court cannot look at the Bankruptcy Code alone because this case involves a governing Bankruptcy Plan. And that Plan does not permit maintaining Wellpath as a nominal defendant. Indeed, the Plan specifies that Wellpath’s Liquidating Trust is the proper entity to pursue in a nominal capacity:

Holders of personal injury tort and wrongful death Claims against the Debtors are subject to the Trust Distribution Procedures (“TDPs”), including the non-binding alternative dispute resolution process set forth therein to determine, if necessary, the allowed amount for their Claim. Such holders of personal injury tort and wrongful death claims may also seek determinations of the Debtors’ liability by the appropriate civil court pursuant to 28 U.S.C. § 157(b)(5) with the Liquidating Trust as a nominal party (a) to the extent such inclusion is necessary to recover against available third-party insurance proceeds or an unreleased Non- Debtor Defendant, or (b) to establish or liquidate the amount of their claim for distribution under the Plan from the Liquidating Trust…. (ECF No. 20-4, PageID.393 (General Form of Order Regarding Lift Stay Motions from the Bankruptcy Court).) So Kalchert, as the holder of constitutional tort claims, may proceed against Wellpath pursuant to the alternative dispute resolution (ADR)

procedures set forth in the Bankruptcy Plan, which would take place in the Bankruptcy Court. (See ECF No. 30-8, PageID.1123.) Or he may litigate against Wellpath’s Liquidating Trust as a nominal party for the purpose of establishing liability in this Court. 28 U.S.C. § 157(b)(5). But, in light of the Bankruptcy Plan, he may not maintain Wellpath itself as a nominal defendant.1 Several other courts in this Circuit have reached the same conclusion. See Lee

v. Wellpath Corp., No. 24-39, 2025 WL 3898108, at *2 (W.D. Mich. Dec. 10, 2025), report and recommendation adopted, No. 24-39, 2026 WL 36576, at *1 (W.D. Mich. Jan. 6, 2026) (granting Wellpath’s motion to dismiss based on the bankruptcy order); Wilhite v. Parr-Mirza, No. 24-11815, 2025 WL 3166810, at *4 (E.D. Mich. Oct. 23, 2025) (granting Wellpath’s motion to dismiss “based on bankruptcy discharge and confirmation order” but “without prejudice to [plaintiff] seeking any appropriate relief in the U.S. Bankruptcy Court for the S.D. Tex. or in the Court of Appeals for the Fifth

Circuit”); Altantawi v. Bouchard, No. 22-11906, 2025 WL 3491556, at *4 (E.D. Mich. Oct. 20, 2025), report and recommendation adopted, No. 22-11906, 2025 WL 3281534 (E.D. Mich. Nov. 25, 2025) (granting motion to dismiss “without prejudice to

1 Kalchert appears to recognize this reality. (ECF No. 28, PageID.701.) (“Plaintiff intends to file a Motion to Request Leave to amend the Complaint to add the Wellpath Liquidating Trust as a nominal defendant.”) There has been no such request, but as described below, Kalchert is granted leave to amend to do so. Plaintiff’s right to seek any appropriate relief” in the bankruptcy court); Jones v. Correct-Care Sols., No. 23-70, 2025 WL 2553486, at *10 (W.D. Ky. Sept. 4, 2025) (granting Wellpath’s motion to dismiss and specifying that to participate in ADR with

the Liquidating Trust, that motion must be filed in the bankruptcy court or with the administrators of the Liquidating Trust).

Now to the individual defendants, who, like Wellpath, seek relief under Federal Rule of Civil Procedure 12(b)(6) “and/or” Rule 56. (ECF No.

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Related

§ 1983
42 U.S.C. § 1983
§ 524
11 U.S.C. § 524
§ 157
28 U.S.C. § 157

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Joshua Kalchert v. Cynthia Adamek et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/joshua-kalchert-v-cynthia-adamek-et-al-mied-2026.