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Diocese of Rochester Chapter 11 — CNA Motion to Seal Denied

The United States Bankruptcy Court for the Western District of New York denied CNA Continental Insurance Company's ex parte motion to file its 72-page objection to confirmation under seal in the Chapter 11 case of the Diocese of Rochester (Docket No. 19-20905-PRW). The Court held on July 22, 2025 that a confidentiality order does not displace the court's duty to scrutinize seal requests under 11 U.S.C. § 107(b), and that neither the § 107(b)(1) commercial-information exception nor the § 107(b)(2) scandalous-or-defamatory exception applies to the litigation-financing information contained in CNA's objection. The existence of a prior confidentiality order or confidentiality agreement is not outcome determinative; a movant must demonstrate one of the two § 107(b) exceptions to seal filings from public view.

Diocese of Buffalo NY Third-Party Release Consent Requirements

The United States Bankruptcy Court for the Western District of New York held that third-party releases in a Chapter 11 reorganization plan require explicit opt-in consent from creditors—rejecting the opt-out approach advocated by the Diocese of Buffalo and its Official Committee of Unsecured Creditors. The court followed the U.S. Supreme Court's Harrington v. Purdue Pharma L.P. ruling that the Bankruptcy Code does not authorize non-consensual third-party releases except in asbestos cases. The Diocese filed Chapter 11 in February 2020 amid over 900 sexual abuse claims, and the disputed joint reorganization plan filed October 1, 2025 proposed releasing parishes and affiliated entities. The U.S. Trustee had objected to the plan's consent mechanism, arguing that only affirmative opt-in should bind creditors to third-party releases. The Diocese and Committee had argued that adequate disclosure and notice could establish consent through absence of opposition (opt-out).

Robert Todd Houle Chapter 7 Bankruptcy Dismissal With 2-Year Filing Injunction

The U.S. Bankruptcy Court for the Western District of New York dismissed Chapter 7 Case No. 25-20223 for cause under 11 U.S.C. § 707(a) due to debtor Robert Todd Houle's failure to provide identification and be examined under oath as required by § 343. The court imposed a two-year filing injunction (longer than the one-year requested by the U.S. Trustee) running in rem with the property at 1108 Cheese Factory Road, Town of Mendon, New York, to prevent Houle from using serial bankruptcy filings to stall foreclosure proceedings. Any bankruptcy petition filed during the two-year period purporting to affect the property will not receive the benefit of the automatic stay under § 362(d)(4)(B).