Michigan Self-Insurers' Security Fund v. DPH Holdings Corp. (In Re DPH Holdings Corp.)
The Michigan Self-Insurers’ Security Fund appealed a bankruptcy court's denial to file late claims against DPH Holdings, Inc., following DPH's Chapter 11 reorganization. The Fund, which covers workers' compensation for insolvent self-insured employers, filed claims three years after the Bar Date, arguing excusable neglect due to DPH's initial commitment to continue payments. The bankruptcy court, however, found no excusable neglect, highlighting the Fund's failure to file a contingent claim by the deadline. The District Court affirmed this decision, emphasizing the significant delay, the potential prejudice to the debtor, and the Fund's legally mistaken belief regarding its claim obligations.