Sumpter v. DPH Holdings Corp.
District Court, S.D. New York · 2012-02-22 · cited 23×
In Sumpter v. DPH Holdings Corp., James Sumpter appealed a Bankruptcy Court order denying his motion for equitable recoupment of between $68 million and $145 million from the reorganized Delphi debtors on behalf of salaried retirees, based on the termination of other post-employment benefits (OPEB) plans during the 2005 bankruptcy proceedings. The District Court affirmed the denial, limiting the appeal to Sumpter’s individual claims for recoupment of uncollected, unreimbursed, pending, or future benefits and a declaratory judgment relieving him of future payment obligations. The court reasoned that the Bankruptcy Court had properly authorized termination of unvested OPEB plans under § 1114, that a subsequent settlement agreement approved by the Retirees’ Committee (from which Sumpter had resigned) resolved objections in exchange for concessions like an $8.75 million payment, and that Sumpter had not demonstrated unjust enrichment or any procedural deficiency that would support recoupment.