In re U.S. Truck Co.
United States Court of Appeals for the Sixth Circuit
800 F.2d 581 (1986)
U.S. Truck Company (defendant), an intrastate shipper in chapter 11, got court approval to reject its collective bargaining agreement; every affected local union but one negotiated new agreements, leaving the Teamsters National Freight Industry Negotiating Committee (plaintiff) as the lone dissenter, whose unsecured claim arose from that rejected agreement. In its reorganization plan, U.S. Truck placed the Teamsters' claim in its own separate voting class (Class IX), apart from a broader class of unsecured creditors holding claims over $200, including other executory-contract-rejection claims (Class XI). The Teamsters objected that this was impermissible gerrymandering of creditor classes designed to secure a favorable confirmation vote. The district court disagreed, finding the separate classification justified because the Teamsters' interests differed substantially from Class XI's, and the Teamsters appealed.
Whether a Chapter 11 debtor may place two unsecured claims that are legally similar as to the bankruptcy estate into separate classes, where the classes otherwise hold substantially different interests regarding the reorganized entity.