Mallinckrodt plc

CourtUnited States Bankruptcy Court, D. Delaware
DecidedApril 19, 2023
Docket20-12522
StatusUnknown

This text of Mallinckrodt plc (Mallinckrodt plc) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mallinckrodt plc, (Del. 2023).

Opinion

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re: ) Chapter 11 ) MALLINCKRODT PLC., et al., ) Case No. 20-12522 (JTD) ) Reorganized Debtors. ) Re: D.I. 8582, 8599, 8604 __________________________________________)

MEMORANDUM OPINION AND ORDER The State of Texas seeks to prevent its political subdivisions from recovering attorneys’ fees from certain distributions under Mallinckrodt’s Plan of Reorganization and related Trust Documents.1 Specifically, Texas seeks to prevent the recovery of attorneys’ fees from distributions provided by the National Opioid Abatement Trust II (“NOAT II Trust”) designated as Abatement Distributions.2 Texas argues that Abatement Distributions under NOAT II Trust can only be used for specified activities designed to abate the national opioid crisis. Instead, Texas contends, the Holders of Municipal Opioid Claims, including its own political subdivisions, must look to a separate fund established under the Plan which provides the exclusive source for the payment of attorneys’ fees.3 The Texas Plaintiffs Steering Committee (“Texas PSC”), on behalf of Texas Holders of Municipal Opioid Claims,4 opposes the motion on two grounds: (i) the Bankruptcy Court does not have core jurisdiction to hear the Motion and should abstain from hearing it as a matter of comity to allow a Texas state court to determine

1 Motion of the States of Texas to Interpret and Enforce the Mallinckrodt Plan and Confirmation Order (the “Motion”), D.I. 8582; Reply to the Response of the Texas Plaintiffs’ Steering Committee in Opposition to the Motion of the State of Texas to Interpret and Enforce the Mallinckrodt Plan and Confirmation Order, D.I. 8604. 2 Capitalized terms not defined in this opinion have the meaning ascribed to them in the Plan and related Trust Documents. 3 The Reorganized Debtors and the Governmental Plaintiff Ad Hoc Committee joined Texas in opposing the payment of attorneys’ fees from the Abatement Distributions. See D.I. 8607 and 8605. 4 The Texas PSC filed a motion in a Texas state court multi-district litigation proceeding seeking the payment of attorneys’ fees from Abatement Distributions under the Plan (“Texas PSC State Court whether Abatement Distributions can be used to pay attorneys’ fees; and (ii) even if the Court hears the Motion, the Plan allows for the payment of attorneys’ fees from NOAT II Trust Abatement Distributions.5 After considering the parties’ submissions and oral arguments, and for the reasons discussed below, the Texas PSC’s objections are overruled and Motion is granted

as set forth below. JURISDICTION AND VENUE Venue is proper pursuant to 28 U.S.C. § 1409(a). This is a core proceeding pursuant to 28 U.S.C. §§ 157(b) and 1334.6 BACKGROUND The Mallinckrodt Plan of Reorganization established a number of trusts to administer and distribute a $1.725 billion fund to satisfy opioid related claims against the Debtors’ estates. Under the Plan, different types of opioid related claims are channeled to various trusts for processing and payment. The Plan required the creation of a Master Distribution Trust (“MDT II Trust”) to receive settlement funds and distribute them to the various trusts to which the different types of claims are channeled.7 The NOAT II Trust, was created for the channeling of

all State and Municipal Opioid Claims.8 The purpose of the trust is to distribute funds to be used to abate the opioid crisis in states and municipalities throughout the United States, and to provide for the payment of costs, including attorneys’ fees for those entities. The Plan further provides that: “Distributions made by NOAT II in respect of Municipal Opioid Claims shall be used solely for Approved Uses, in accordance with the NOAT II

5 Response of the Texas Plaintiff’s Steering Committee in Opposition to the Motion of the State of Texas to Interpret and Enforce the Mallinckrodt Plan and Confirmation Order, D.I. 8599. 6 The Texas PSC’s jurisdictional arguments are addressed in greater detail below. 7 D.I. 6510 at 94 (Plan Art. IV.T). 8 D.I. 6510 at 68 (Plan Art. III.B.8). Documents.”9 Approved Uses under the Plan is defined simply as Authorized Abatement Purposes.10 Authorized Abatement Purposes, in turn, is defined to mean: with respect to any Abatement Trust, (i) an authorized opioid abatement purpose for which an Abatement Distribution from such Abatement Trust may be used, as set forth in the Abatement Trust Documents for such Abatement Trust, or (ii) the payment of attorneys’ fees and costs of Holders of Opioid Claims channeled to such Abatement Trust (including any counsel to any ad hoc group or other group of such Holders, including any such counsel that is not a Retained Professional).11

In order to accomplish these twin goals while ensuring that the vast majority of the available funds went to abate the opioid crisis, the Plan required the establishment of separate funds for the payment of State, Municipal and Tribe12 attorneys’ fees.13 Under the Plan, the Municipal and Tribe Opioid Attorneys’ Fee Fund is to be funded in an amount not to exceed $110 million. The State Opioid Attorneys’ Fee Fund is to be funded in an amount not to exceed $90 million. The Plan clearly and unequivocally states that: Payments from the Municipal and Tribe Opioid Attorneys’ Fee Fund shall be the exclusive means of payment from the Public Opioid Creditor Trusts14 for costs and expenses (including attorneys’ fees) of any Holder of a Municipal Opioid Claim or Tribe Opioid Claim (or any ad hoc group consisting of any of the foregoing) or any attorney therefor, other than amounts paid in accordance with the order of the MDL Court establishing the Common Benefit Fund.15

9 D.I. 6510 at 69 (Plan Art. III.B.8.b). “NOAT II Documents” means the documents governing: (a) the NOAT II; (b) the flow of consideration from the Opioid MDT II to the NOAT II; (c) submission, resolution, and distribution procedures in respect of all State Opioid Claims and Municipal Opioid Claims (including, in each case, Opioid Demands); and (d) the flow of Abatement Distributions to Authorized Recipients, including distributions, payments or flow of funds made from the NOAT II after the Effective Date. D.I. 6510 at 32 (Plan Art. I.A.263). 10 D.I. 6510 at 9 (Plan Art. I.A.42). 11 D.I. 6510 at 11 (Plan Art. I.A.58). 12 D.I. 6510 (Plan Art. IV.X). Tribe Opioid Abatement Claims are channeled to a separate trust, the Tribal Abatement Fund Trust II (“TAFT II”). D.I. 7684 at 142 (TAFT II Documents § 1.2). 13 D.I. 6510 at 106 (Plan Art. IV.X.9.A) (“Opioid Attorneys’ Fee Fund. On the Effective Date, the Opioid Attorneys’ Fee Fund shall be established, and thereafter funded pursuant to Article IV.X.7 for payment of costs and expenses (including attorneys’ fees) as further set forth in this Article IV.X.9”). 14 Public Opioid Creditor Trusts means the NOAT II and TAFT II. D.I. 6510 at 43 (Plan Art. I.A.349). 15 D.I. 6510 at 106 (Plan Art. IV.X.9.A) (emphasis added). Not all Abatement Trusts are required to establish a separate attorneys’ fee fund under the Plan. Consistent with the requirements set forth in the Plan, the MDT II Trust Agreement which is responsible for distribution of trust assets to the various Opioid Creditor Trusts, requires that all distributions from the MDT II Trust are to be in accordance with the Plan and the MDT II Trust Agreement.16 Moreover, the MDT II Trust Agreement provides that the trustees must

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