Sanders v. Prince, et al.

Summary

The United States District Court for the Middle District of Pennsylvania grants a Rule 12(b)(6) motion to dismiss claims against two medical defendants in a prisoner civil-rights action alleging inadequate medical care. The court concludes that the defendants, as current or former Wellpath employees, are protected by the third-party release and injunction in Wellpath’s confirmed Chapter 11 bankruptcy plan because the plaintiff did not timely opt out. The claims are dismissed without prejudice to pursuing appropriate relief through the bankruptcy court, and amendment in the district court is deemed futile.

Holdings

1. Sanders's claims against Prince and Abel were barred by the third-party release and permanent injunction contained in Wellpath's confirmed Chapter 11 plan because the claims arose before the bankruptcy petition date and Sanders did not timely opt out.
2. Leave to amend was denied because amendment would be futile; the claims against the medical defendants were dismissed without prejudice to Sanders's right to pursue appropriate relief through the bankruptcy court.

Questions Presented

1. Whether Sanders's claims against Wellpath employees were barred by the third-party release and injunction in Wellpath's confirmed Chapter 11 plan because Sanders did not timely opt out.
2. Whether the claims against the medical defendants should be dismissed without prejudice and without leave to amend because amendment would be futile.

Disposition

dismissed