In re Piper Aircraft
United States Court of Appeals for the Eleventh Circuit
58 F.3d 1573 (1995)
Piper Aircraft Corporation (Piper) filed for chapter 11 reorganization and, as part of its plan, agreed to sell its assets to Pilatus Aircraft Limited, which required Piper to have a representative appointed for "Future Claimants" — anyone who might, after plan confirmation, assert product-liability claims based on Piper products made or sold before confirmation. David Epstein (Epstein), appointed as that representative, filed a roughly $100 million proof of claim based on statistical assumptions about future claimants who had no actual prepetition contact with Piper or its products. The bankruptcy court disallowed the claim for lack of any prepetition relationship between the Future Claimants and Piper, the district court affirmed, and Epstein appealed.
Whether a group of unidentified persons who might, in the future after confirmation of a debtor manufacturer's reorganization plan, commence actions for damages arising from products designed, made, sold, or distributed by the debtor before confirmation, may file a proof of claim against the debtor in the bankruptcy.