Korean v. Debtor's Representatives

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 14, 2019
Docket18-1040
StatusUnpublished

This text of Korean v. Debtor's Representatives (Korean v. Debtor's Representatives) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Korean v. Debtor's Representatives, (6th Cir. 2019).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 19a0020n.06

No. 18-1040

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

In re: SETTLEMENT FACILITY DOW ) CORNING TRUST. ) FILED _______________________________________ ) Jan 14, 2019 ) DEBORAH S. HUNT, Clerk KOREAN CLAIMANTS, ) ) Interested Parties - Appellants, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE EASTERN ) DISTRICT OF MICHIGAN DEBTOR’S REPRESENTATIVES; DOW ) CORPORATION; CLAIMANTS’ ADVISORY ) COMMITTEE, ) ) Defendants-Appellees. ) )

BEFORE: ROGERS, STRANCH, and THAPAR, Circuit Judges.

ROGERS, Circuit Judge. Facing bankruptcy, Dow established a trust to pay out claims

arising from injuries and diseases allegedly caused by Dow breast implants.1 A group of South

Korean claimants filed motions regarding their claims: one motion seeking reversal of certain

decisions made by the administrators of the claims process, and one asking the claims

administrator to re-categorize South Korea as a richer country so that the Korean Claimants would

receive higher settlements. The claims administrator reversed the decisions and re-categorized

1 Dow Corning Corporation changed its name to Dow Silicones Corporation effective February 1, 2018, so for convenience, we refer to appellants as Dow throughout. No. 18-1040, Korean Claimants v. Debtor’s Representatives, et al.

South Korea, rendering the Korean Claimants’ motions largely moot. The district court found that

the motions were moot, and to the extent they requested further relief, they failed on the merits.

On appeal, the Korean Claimants challenge this decision, arguing that the specific relief they

requested has not been granted, but their arguments amount to unfounded or improperly raised

requests for additional relief.

I.

This appeal concerns Dow breast-implant claims made pursuant to a bankruptcy plan.

These types of claims and this plan have been discussed by this court before. See In re Settlement

Facility Dow Corning Tr., 628 F.3d 769 (6th Cir. 2010); In re Dow Corning Corp., 280 F.3d 648

(6th Cir. 2002); In re Dow Corning Corp., 86 F.3d 482 (6th Cir. 1996). Briefly, Dow declared

bankruptcy in 1995 in response to “thousands of lawsuits relating to breast implants it had

manufactured.” In re Settlement Facility, 628 F.3d at 771. After much negotiation and legal

process, Dow’s Amended Joint Plan of Reorganization became effective June 1, 2004. Under the

plan, breast-implant claimants who wish to settle their claims can do so with the Settlement

Facility-Dow Corning Trust—a $1.95 billion fund established to pay these types of claims. See

id.

The Korean Claimants are a group of South Koreans who have submitted claims to the

Settlement Facility and are represented by Mr. Yeon Ho Kim. Through Mr. Kim, the Korean

Claimants submitted hundreds of claims that used the same type of evidence to prove that Dow

was the manufacturer of their breast implants: an “affirmative statement” from their physicians

that reads as follows:

The undersigned physician attests that the above patient received breast implant surgery from our hospital and the product used for surgery is a Dow Corning product *Basis: The medical records at that time were destroyed because a ten year period of keeping medical records passed by. However, this hospital only used

-2- No. 18-1040, Korean Claimants v. Debtor’s Representatives, et al.

Dow Corning products during a period of this operation thus the product used for the above patient can be attested as a Dow Corning product[Date][Signature of implanting physician].

In 2006, the Settlement Facility began having doubts about this proof. According to the

Settlement Facility, there were several odd things about the Korean Claimants’ claims. Under the

plan documents, affirmative statements in general are disfavored, and are only permitted as proof

of manufacturer if there are no medical records. But the number of Korean Claimants’ claims

relying on an affirmative statement was very high: over 94% of Mr. Kim’s clients submitted

affirmative statements as proof of manufacturer, higher than every other law firm that had

submitted more than 100 claims. In other words, almost every Korean Claimant appeared to be

unable to locate her medical or hospital records. There were other oddities as well. On some

claims the date and facility listed for the procedure would be different on the affirmative statement

than the date on registration forms. Correction fluid was used on many forms. Perhaps most

troublingly, when questioned regarding these, and similar, documentation problems, Mr. Kim

apparently sent the Settlement Facility medical documentation as proof, despite his representation

that there were no medical records for these operations. According to Mr. Kim, he used the

affirmative statements because the Settlement Facility had agreed that they would be acceptable

proof of manufacturer.

After noticing these various problems, the Settlement Facility put the brakes on processing

certain claims filed by the Korean Claimants. In August 2011, the Settlement Facility informed

Mr. Kim that it was no longer processing claims supported by these affirmative statements. In

their briefs before us, all of the parties refer to these actions as an administrative “hold.”

In response to the August 2011 letter informing Mr. Kim of the hold, the Korean Claimants

filed a “Motion for Reversal of Decision of [the Settlement Facility] Regarding Korean

-3- No. 18-1040, Korean Claimants v. Debtor’s Representatives, et al.

Claimants.” In this motion, the Korean Claimants argued that the Claims Administrator, the person

tasked under the plan with administering claims, should not have instituted the hold. The motion

was short on law. It did not cite a provision of the plan documents that would have prevented the

Claims Administrator from instituting the hold, nor any provision of those documents that entitled

the Korean Claimants to federal court review of the Claims Administrator’s decision. Dow and

the Settlement Facility filed motions to dismiss this Motion for Reversal. They argued that the

Claims Administrator’s decisions regarding the veracity of a claim or eligibility of a claimant could

not be appealed to the district court.

More than two years later, while the Korean Claimants Motion for Reversal was still

pending, the Settlement Facility withdrew the hold. The Claims Administrator wrote in a January

2014 email to Mr. Kim that the Settlement Facility “will review and process your claims consistent

with the Plan of Reorganization.” Mr. Kim replied, “All of the Korean Claimants will appreciate

. . . your decision on withdrawal from the exclusion of processing.”

Months later, the Korean Claimants, through Mr. Kim, filed a “Motion for Re-

Categorization of Korea.” Under the plan, countries are categorized differently based on their per-

capita Gross Domestic Product (GDP). Broadly speaking, claimants from poorer countries receive

smaller settlements. When the Korean Claimants filed their motion, South Korea was a Category

3 country, defined to include countries with between 30 and 60% of the per-capita GDP of the

United States.

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