Westport Insurance Corporation v. The Official Committee of Unsecured Creditors of the Roman Catholic Archbishop of San Francisco

CourtDistrict Court, N.D. California
DecidedDecember 10, 2025
Docket3:25-cv-09314
StatusUnknown

This text of Westport Insurance Corporation v. The Official Committee of Unsecured Creditors of the Roman Catholic Archbishop of San Francisco (Westport Insurance Corporation v. The Official Committee of Unsecured Creditors of the Roman Catholic Archbishop of San Francisco) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Westport Insurance Corporation v. The Official Committee of Unsecured Creditors of the Roman Catholic Archbishop of San Francisco, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 WESTPORT INSURANCE Case No. 25-cv-09314-WHO CORPORATION, 8 Plaintiffs, ORDER WITHDRAWING 9 REFERENCE v. 10 Re: Dkt. Nos. 6, 26 THE OFFICIAL COMMITTEE OF 11 UNSECURED CREDITORS OF THE ROMAN CATHOLIC ARCHBISHOP OF 12 SAN FRANCISCO, Defendant. 13 14 15 Westport Insurance Corporation (“Westport”) brought a declaratory relief action in the 16 United States Bankruptcy Court for the Northern District of California (the “Bankruptcy Court”) 17 against debtor the Roman Catholic Archbishop of San Francisco (“RCASF”), seeking to clarify 18 whether Westport has any obligation under its insurance policy to defend or indemnify the 19 RCASF in its ongoing sexual abuse court actions. Westport now seeks to withdraw the insurance 20 coverage dispute from the Bankruptcy Court to this court under 28 U.S.C. § 157(d). For the 21 reasons described below, Westport’s motion to withdraw reference is GRANTED. 22 BACKGROUND 23 Westport entered a prepetition liability contract with the RCASF to provide “excess 24 liability coverage” for a period running from July 8, 1972 to July 8, 1975 (Excess Policy No. 25 U10447) (the “Policy”). See Notice of Motion (“Mot.”) [Dkt. No. 6] at 3. The policy provided 26 coverage for “loss in excess of the limits of underlying insurance and resulting from an 27 ‘occurrence.’” Id. An “occurrence” was defined by the policy as including “an accident, 1 injury or property damage neither expected nor intended from the standpoint of the Insured.” Id. 2 The RCASF has faced increased scrutiny in recent years by survivors of child sexual 3 abuse. Id. When the California Legislature removed the statute of limitations to bring forth claims 4 alleging childhood sexual abuse, approximately 537 lawsuits were filed against the RCASF 5 alleging sexual abuse by clergy or others associated with it. Id. at 3–4 (referencing Cal. Civ. Proc. 6 Code § 340.1(q)). Given the sudden increased volume of litigation, the RCASF filed for Chapter 7 11 Bankruptcy in the Bankruptcy Court on August 21, 2023. Mot. at 4–5. 8 Westport alleges that the RCASF has tendered to them “over 100 Underlying Claims for 9 which the [RCASF] seeks coverage under the Policy.” Mot. at 5. As a result, on October 8, 2025, 10 Westport filed a complaint in the Bankruptcy Court, seeking declaratory judgment that the Policy 11 does not provide coverage to the RCASF in various circumstances, as well as a jury trial on all 12 disputed issues. Id. at 5–6. Westport “contemporaneous[ly]” filed a motion to withdraw the 13 reference to the Bankruptcy Court in order to have the matter heard in this one. See id. On 14 November 17, 2025, the RCASF filed a statement of non-opposition to Westport’s motion. See 15 Statement of Non-Opposition (“Non-Oppo.”) [Dkt. No. 26] at 1. 16 DISCUSSION 17 Under 28 U.S.C. § 1334(b), district courts retain “original but not exclusive jurisdiction” 18 over all bankruptcy proceedings. These proceedings include “core proceedings, in which the 19 bankruptcy court may enter appropriate orders and judgments,” and “non-core proceedings, which 20 the bankruptcy court may hear but for which it may only submit proposed findings of fact and 21 conclusions of law to the district court for de novo review.” Sec. Farms v. Int’l Brotherhood of 22 Teamsters, Chauffers, Warehousemen & Helpers, 124 F.3d 999, 1008 (9th Cir. 1997) (quoting 28 23 U.S.C. § 157) (internal quotation marks omitted). “Actions that do not depend on bankruptcy laws 24 for their existence and that could proceed in another court are considered ‘non-core.’” Id. 25 District courts have the authority to withdraw reference to the bankruptcy court under 28 26 U.S.C. § 157(d). That section allows for both permissive and mandatory withdrawal. Id. 27 Mandatory withdrawal is required if “resolution of the proceeding requires consideration of both 1 interstate commerce.” Id. Permissive withdrawal, however, requires a showing that the party 2 moved in a “timely” manner and shows “cause” in support of its request. Id. “In determining 3 whether cause exists, a district court should consider the efficient use of judicial resources, delay 4 and costs to the parties, uniformity of bankruptcy administration, the prevention of forum 5 shopping, and other related factors.” Sec. Farms, 124 F.3d at 1008. 6 Westport contends that permissive withdrawal is appropriate in this case because (1) much 7 of the dispute involves jury issues that cannot be resolved by a bankruptcy court; (2) the claims at 8 issue involve “exclusively state-law matters . . . that by definition do not arise under the 9 Bankruptcy Code or in the Bankruptcy Case”; and (3) withdrawal will “promote the efficiency, 10 economy, and other policy considerations that animate the referral power.” Mot. at 1–2. Westport 11 also claims that the reference “must be withdrawn eventually” and doing so “now will prevent 12 ongoing harm to the administration” of the underlying bankruptcy proceeding. Id. at 2. The 13 RCASF does not oppose withdrawal of the reference because the insurance coverage dispute 14 involves “non-bankruptcy law” and potentially triable issues before a jury but does not “concede 15 or admit . . . the underlying claims or allegations” asserted in the insurance coverage dispute. 16 Non-Oppo. at 1. I agree that there is good cause to withdraw the reference here. 17 A. The Motion is Timely. 18 A withdrawal request is timely if brought “as promptly as possible in light of the 19 developments in the bankruptcy proceeding.” Sec. Farms, 124 F.3d at 1007 n.3 (quoting In re 20 Baldwin-United Corp., 57 B.R. 751, 754 (S.D. Ohio 1985)). Courts have found that motion for 21 withdrawal is timely if filed within days of the underlying complaint in bankruptcy court. See, 22 e.g., Roman Cath. Diocese of Rockville Ctr. v. Certain Underwriters at Lloyds, London & Certain 23 London Mkt. Cos., 634 B.R. 226, 233 (S.D.N.Y. 2021) (eight days after answer); Sec. Farms, 124 24 F.3d at 1107 n.3 (six days after removal from state court). 25 Westport’s motion is timely under Section 157(d). Westport moved for withdrawal of the 26 reference “mere minutes after filing the Complaint that initiated the proceeding.” Mot. at 7. This 27 certainly qualifies as a “timely” motion to withdraw reference. B. There is Cause to Withdraw. 1 1. Judicial Efficiency 2 The next step in the analysis is deciding whether Westport’s claims are core or non-core, as 3 “it is upon this issue that questions of efficiency and uniformity will turn.” Hjelmeset v. Cheng 4 Hung, No. 17-CV-05697-BLF, 2018 WL 558917, at *3 (N.D. Cal. Jan. 25, 2018). Bankruptcy 5 judges are “limit[ed] [by the Constitution] to adjudicate—i.e., to render a final judgment—to 6 issues that are at the ‘core’ of the bankruptcy power.” In re Harris, 590 F.3d 730, 737 (9th Cir. 7 2009). If a proceeding is “core,” then “[b]ankruptcy judges may hear and determine” it on a final 8 basis, subject to appellate review. 28 U.S.C. § 157(b)(1). If a proceeding is “non-core,” however, 9 then a bankruptcy court must prepare “proposed findings of fact and conclusions of law” for 10 submission to “the district court,” who must then enter “final . . . judgment” on the claim “after 11 considering the bankruptcy judge’s proposed findings and conclusions and . . . reviewing de novo” 12 all “matters to which any party has [properly] objected.” 28 U.S.C.

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Westport Insurance Corporation v. The Official Committee of Unsecured Creditors of the Roman Catholic Archbishop of San Francisco, Counsel Stack Legal Research, https://law.counselstack.com/opinion/westport-insurance-corporation-v-the-official-committee-of-unsecured-cand-2025.