ADA Claim Arose Prepetition and Was Discharged by Confirmation

The following is a summary of a Minnesota bankruptcy case or a case relevant to Minnesota bankruptcy law.

Minnesota Bankruptcy Case:

Sanchez v. Northwest Airlines, Inc., 432 B.R. 803 (D. Minn. 5/21/10) (Kyle, J.).

Case Summary:

ADA Claim Arose Prepetition and Was Discharged by Confirmation

Sanchez, a former NWA employee, sued NWA for an alleged violation of the Americans with Disabilities Act. On the parties’ cross-motions for summary judgment, the court denied Sanchez’s motion and granted NWA’s motion, holding that Sanchez’s claim was discharged in NWA’s bankruptcy.

Sanchez did not file his complaint until more than a year after the effect date of NWA’s chapter 11 plan confirmation. The court found that Sanchez’s ADA claim existed on the effective date of NWA’s confirmed reorganization plan. Sanchez argued that at that time, he was still fighting for an accommodation, so he had no right to payment and thus no claim. However, the court ruled that the fact that the claim might have been unliquidated, contingent, unmatured, or disputed, did not mean that it was not a claim. The court was not convinced by Sanchez’s second argument, that his claim should survive because NWA continued to violate the ADA after confirmation. The actions taken by NWA that Sanchez said constituted a continuing violation were not, the court found, post-confirmation discrimination or a continuing violation. The court also rejected Sanchez’s due process argument because it found that Sanchez was mailed notices regarding the bar dates for filing claims, and he received those notices before AND after his claim arose. Finally, the court saw no equitable reason to allow Sanchez’s discharged ADA claim to proceed.

Credit: The preceding was a summary of a case relevant to Minnesota bankruptcy law. The case summary was prepared by the U.S. Bankruptcy Court through Judge Robert J. Kressel & attorney Faye Knowles.

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