Matter of Computerized Steel Fabricators, Inc.
The reorganized Chapter XI debtor, Computerized Steel Fabricators, Inc., initiated a motion to hold Pension Fund Iron Workers Local 455 in contempt. Computerized argued that its Chapter XI confirmation order discharged any potential withdrawal liability under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), which the Pension Fund was attempting to collect post-confirmation. However, the court determined that Computerized's collective bargaining agreement was not rejected during bankruptcy and remained in effect, and thus the withdrawal liability arose in June 1982, post-confirmation, when Computerized ceased operations. The court held that this post-confirmation claim was not provable or dischargeable under the Bankruptcy Act and that the MPPAA's application was constitutional and not retroactive. Consequently, the application to hold the Pension Fund in contempt was denied.