Can Unsecured Creditors File Claims for Legal Fees Incurred Post-Petition, Based Upon a Pre-Petition Agreement?

January 22, 2013 | 885 Comments
Posted by Donald F. Campbell, Jr.

On March 20, 2007, the Supreme Court, in Travelers Casualty and Surety Co. of America v. PG&E Co., 549 U.S. (2006), found that Bankruptcy law does not prevent unsecured creditors from claiming post-petition legal fees otherwise reimbursable pursuant to terms of a pre-petition contract. In Travelers, PG&E filed a Chapter 11 Bankruptcy in April of 2001. Prior to such filing, Travelers issued a $100 million dollar surety bond on PG&E’s behalf guaranteeing PG&E’s payment of state workers’ compensation benefits. In connection with the surety bond, PG&E agreed to indemnify Travelers against any loss Travelers may incur due to PG&E’s connection with the bonds, including any legal fees incurred in pursuing, protecting or litigating Traveler’s rights in connection with the bonds. Travelers incurred legal fees in Traveler’s bankruptcy proceedings and filed a general unsecured claim for such fees. PG&E objected to the claim arguing that Travelers could not recover attorney’s fees incurred while litigating issues of bankruptcy law.

The Bankruptcy Court agreed and rejected Traveler’s claim based upon the long-standing “Fobian rule” first developed in In re Fobian, 951 F.2d 1149 (CA9 1991), which states that, absent bad faith or harassment by the losing party, attorney’s fees will not be awarded if the litigated issues involve issues peculiar to federal bankruptcy law. Other circuits rejected the Fobian rule resulting in a split by the Circuit Courts. The Supreme Court in Travelers ended the division finding that the contract-based claims for attorney’s fees incurred litigating issues of bankruptcy law are allowed. The Court focused on 11 U.S.C. §502(b), which set forth nine specific exceptions any of which will result in the disallowance of a claim. None of the nine exceptions preclude post-petition attorney fees. The Court determined that a creditor’s rights arise under substantive state law and Congress has left the determination of property rights in assets of a bankrupt’s estate to state law. In other words, if state law permits a party to the reimbursement of attorney fees, then the bankruptcy court must honor the state law and cannot overrule the creditor’s right to payment.

Travelers is not significant for what it did (overturning Fobian) but for what it did not do. Many Courts have disallowed creditor’s claims for post-petition attorneys pursuant to an interpretation of 11 U.S.C. §506(b). That section of the Code states that an allowed secured creditor is entitled to reimbursement of attorney fees permitted under an agreement or state statute if the value of the property securing their claim is greater than the claim itself. Stated inversely, if a secured creditor incurs legal fees and is entitled to reimbursement from the debtor for such fees under an agreement or statute, a claim for such fees will not be allowed if the creditor is under-secured. Since unsecured creditors are not secured at all, many courts have denied unsecured creditors’ claims for legal fees citing §506(b). PE&G’s brief and arguments to the Court relied not upon Fobian, but their interpretation and lower court reliance upon §506(b); however PE&G did not raise this argument during the appeal and therefore, the Supreme Court would not consider the argument leaving this issue unresolved. Based upon the Court’s strict interpretation of §502(a), unsecured claimants should undoubtedly seek reimbursement of post-petition legal fees. That is, until the Court’s next ruling?

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