Michael Christopher Wibracht

CourtUnited States Bankruptcy Court, W.D. Texas
DecidedMarch 31, 2022
Docket21-50477
StatusUnknown

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

Bluebook
Michael Christopher Wibracht, (Tex. 2022).

Opinion

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Dated: March 31, 2022. Cancy A CRAIG A. oh CHIEF UNITED STATES BANKRUPTCY JUDGE

IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION IN RE: § CASE NO. 21-50477-CAG § MICHAEL CHRISTOPHER WIBRACHT, § § CHAPTER 7 Debtor. §

ORDER DENYING TRUSTEE’S OBJECTION TO CLAIM #20-1 OF LAURA WIBRACHT (ECE NO. 110) This is the Court’s Order on the Trustee’s Objection to Claim #20-1 of Laura Wibracht (ECF No. 110)! (“Objection”). Laura Wibracht filed a Response of Laura Wibracht to the Chapter 7 Trustee’s Objection to Claim #20-1 (ECF No. 136) (“Response”). The Court held a hearing on the matters on February 11, 2022 and took the matters under advisement.

For the forthcoming reasons, the Trustee’s Objection is DENIED.

' “FCF” denotes electronic filing docket number.

JURISDICTION As a preliminary matter, the Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1334. This is a core proceeding under 28 U.S.C. §§ 157(b)(2)(A), (B), (F), and (I). Venue is proper under 28 U.S.C. §§ 1408 and 1409. This case is referred to this Court by the Standing Order of Reference entered in this District.

FINDINGS AND CONCLUSIONS The findings and conclusions set forth herein constitute the Bankruptcy Court’s findings of fact and conclusions of law pursuant to Fed. R. Bankr. P. 7052(a), made applicable to this hearing by Fed. R. Bankr. P. 9014. To the extent that any of the following findings of fact constitute conclusions of law, they are adopted as such. To the extent that any of the following conclusions of law constitute findings of fact, they are adopted as such.

FACTUAL AND PROCEDURAL BACKGROUND Debtor Michael Wibracht filed his voluntary petition of Chapter 7 bankruptcy relief on April 22, 2021 (ECF No. 1). Laura Wibracht thereafter filed two timely claims: claims number 19 and 20. (See Claims Register). Claim Number 19 purports to be for child support (Claim No. 19- 1) and Claim Number 20 purports to be for spousal support (Claim No. 20-1). Laura Wibracht, in other words, asserts that both her claims are priority claims because of their status as domestic

support obligations. (See Claims Nos. 19–20). Trustee moved for (ECF No. 70), and the Court approved (ECF No. 75), an interim distribution paying Laura Wibracht $10,840.15 on Claim 19-1 as a domestic support obligation.

Trustee filed his Objection to Claim 20-1. (ECF No. 110). Trustee’s Objection advanced several arguments to object to allowance of the claim. First, Trustee objects that Claim 19-1, a domestic support obligation also related to the divorce, was paid in full. (Id. at 2). Second, Trustee objects to the claim as a fraudulent transfer based on the state court judgment. (Id. at 3). According to the Trustee, the state court judgment constitutes an obligation, created within 2 years of the bankruptcy petition, to the benefit of an insider under an employment contract not in the ordinary course of business, and for less than reasonably equivalent value. (Id.). Trustee further argues that

Michael Wibracht was not a party to the employment contract, so the obligation incurred by the judgment was involuntary. (Id.). Trustee argues this constitutes a constructively fraudulent transfer, which can be avoided through §§ 502(d) and 548.2 (Id.). Third, Trustee objects to classifying a state court judgment based on an employment contract as a domestic support obligation. (Id.). Lastly, Trustee objects to the judgment granting Laura Wibracht an equitable lien on certain assets of the Debtor because Trustee is aware of no attempt to perfect those liens, so the unperfected lien can be avoided and disallowed through §§ 502(d) and 548. (Id. at 4).

Laura Wibracht then filed the Response. (ECF No. 136).3 The Response denies the majority of allegations made in the Objection. (Id. at 1–2). The Response then lays out the factual and procedural history of the Wibracht divorce and related proceedings. (Id. at 2–4). The Response explains that Michael and Laura Wibracht reached a partial settlement of their divorce by executing an Employment Agreement between Laura Wibracht and 210 DG LLC, one of Michael’s companies on June 23, 2016. (Id. at 2–3). The Employment Agreement provided Laura would be paid $7,000.00 monthly for an eight-year term and that Laura would additionally be entitled to bonuses paid to Michael. (Id. at 3). The Employment Agreement’s effective date is July 1, 2016.

2 Unless otherwise indicated, all section references are to Title 11 U.S.C. – et. seq. 3 Laura Wibracht originally filed her Response at ECF No. 119. An exhibit attached to ECF No. 119 contained the names and dates of birth of minor children. Laura Wibracht filed a Motion to Restrict or Redact Document (ECF No. 132). The Court granted the motion (ECF No. 133) and restricted access to ECF No. 119. Laura Wibracht then again filed a Response with sensitive information redacted (ECF No. 136). (Id. at 11). A day later, on June 24, 2016, the family court entered a Final Decree of Divorce approving the Amended Agreement Incident to Divorce which incorporated the Employment Agreement. (Id. at 2).

The Response further alleges that Michael Wibracht initially made payments to Laura under the Employment Agreement but ceased in October 2017. (Id. at 3). Laura brough her breach claim through arbitration. (Id.). The arbitrator awarded Laura $652,544.26 on January 29, 2019. (Id.). The family court then confirmed the arbitration and entered a final judgment in Laura’s favor in the same amount on April 6, 2021. (Id.).

Citing both the Bankruptcy Code definition and Fifth Circuit precedent, the Response argues that, despite its label, the Employment Agreement constitutes a domestic support obligation between former spouses. (Id. at 4, 6–8). As a domestic support obligation, the Response argues that the claim is not subject to avoidance and must be given priority status, so the Objection should be overruled. (Id. at 8). The Court held a hearing on the matter on February 11, 2022. The Court admitted Trustee’s Exhibits 1–4 and Laura Wibracht’s Exhibits 1–5. At the hearing, the Trustee and Laura Wibracht

advanced substantially the same arguments as contained in the Objection and Response. Trustee argued that the Claim should be disallowed as a domestic support priority claim and instead allow it as a general unsecured claim. In the alternative, Trustee argued that the claim should be avoided and disallowed as a fraudulent transfer under §§ 502(d) and 548. Counsel for Laura Wibracht again argued that courts must look to the substance rather than labels of a disputed document to determine whether it is a domestic support obligation, so, within the context of the divorce, the Employment Agreement is a domestic support obligation and should be allowed with priority status. The Court heard a proffer of testimony from the Trustee. Trustee proffered that he was appointed as Trustee in the case. During the administration of the estate, Trustee liquidated a townhome in Corpus Christi. Trustee proffered that he paid Laura Wibracht’s Claim #19–1 in full.

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