In Re Blue Diamond Coal Co.
This memorandum addresses the debtor's objection to a claim filed by the Southern Labor Union, Local No. 188, seeking damages allegedly arising from interim changes and subsequent rejection of a collective bargaining agreement under Chapter 11. The court considers procedural issues, finding the Union's amended claims timely and the Union having standing as a creditor. However, the core of the decision interprets Bankruptcy Code §§ 1113, 365, and 502(g). The court concludes that § 1113 removed collective bargaining agreements from the purview of § 365 and, crucially, from the damage provisions of § 502(g). Therefore, no statutory basis exists under the current Bankruptcy Code to allow claims for damages resulting from the rejection of a collective bargaining agreement under § 1113. Consequently, the debtor's objection is sustained, and the Union's claims are disallowed.