Gray v. Polar Molecular Corp. (In re Polar Molecular Corp.)

195 B.R. 548 (1996)

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Gray v. Polar Molecular Corp. (In re Polar Molecular Corp.)

United States Bankruptcy Court for the District of Massachusetts
195 B.R. 548 (1996)

SS

Facts

In 1993, Polar Molecular Corporation (Polar) (debtor) filed a Chapter 11 bankruptcy petition. The bankruptcy court replaced Polar’s management with a trustee. Polar’s reorganization plan (plan) was confirmed in 1994. The plan required Polar to make distributions to general unsecured creditors. The distribution amounts depended on Polar’s income, the calculation of which was based on Polar’s gross margin. The plan called for the bankruptcy court to keep jurisdiction over the case in order to interpret the plan, rule on motions and litigated matters filed on or after the plan’s confirmation date, and facilitate payments and performance under the plan. Polar began making payments under the plan. In 1995, Polar asked the bankruptcy court to enter a decree finalizing the bankruptcy proceeding (final decree). On the same day, the trustee filed a complaint alleging that Polar had miscalculated its gross margin and ought to have paid creditors an additional $11,000. Polar asserted that the bankruptcy court lacked subject-matter jurisdiction over the case because the plan had been substantially consummated, meaning that the trustee’s dispute arose under state contract law rather than Title 11.

Rule of Law

Issue

Holding and Reasoning (Feeney, J.)

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