Case: 19-20066 Document: 00515514095 Page: 1 Date Filed: 08/04/2020 United States Court of Appeals for the Fifth Circuit United States Court of Appeals Fifth Circuit FILED August 4, 2020 No. 19-20066 Lyle W. Cayce Clerk In the Matter of: Westmoreland Coal Company, et al, Debtors, Michael H. Holland, as trustee for the United Mine Workers of America Combined Benefit Fund and United Mine Workers of America 1992 Benefit Plan; William P. Hobgood, as trustee for the United Mine Workers of America Combined Benefit Fund; Michael W. Buckner, as trustee for the United Mine Workers of America Combined Benefit Fund; Michael O. McKown, as trustee for the United Mine Workers of America Combined Benefit Fund and United Mine Workers of America 1992 Benefit Plan; Joseph R. Reschini, as trustee for the United Mine Workers of America Combined Benefit Fund and United Mine Workers of America 1992 Benefit Plan; Carlo Tarley, as trustee for the United Mine Workers of America 1992 Benefit Plan; Carl E. Van Horn, as trustee for the United Mine Workers of America Combined Benefit Fund; Gail R. Wilensky, as trustee for the United Mine Workers of America Combined Benefit Fund, Appellants, versus Case: 19-20066 Document: 00515514095 Page: 2 Date Filed: 08/04/2020 Westmoreland Coal Company; Absaloka Coal, L.L.C.; Buckingham Coal Company, L.L.C.; Dakota Westmoreland Corporation; Daron Coal Company; et al, Appellees. Appeal from the United States Bankruptcy Court for the Southern District of Texas USBC No. 4:18-AP-3300 Before Davis, Smith, and Costa, Circuit Judges. Gregg Costa, Circuit Judge: This case involves the interaction of two laws that protect retirees’ health care benefits. Passed in 1992, the Coal Act culminated decades of efforts to guarantee benefits for retired coal miners. It requires coal companies to pay premiums that fund retirees’ benefits and limits interference with those obligations. Enacted four years earlier, section 1114 of the Bankruptcy Code followed a number of high-profile Chapter 11 cases in which debtors—among them, a coal company—unilaterally terminated their retirees’ benefits. It requires a debtor to keep paying benefits unless those benefits are modified through either an agreement between the debtor and the retirees’ representative or a court order. This appeal asks whether section 1114 allows for the modification of Coal Act obligations. In line with every other court that has answered the question, we conclude that it does. I. A. The history of the Coal Act is detailed elsewhere, so we review it only briefly. See generally E. Enterprises v. Apfel, 524 U.S. 498, 504–15 (1998); In re Walter Energy, Inc., 911 F.3d 1121, 1126–32 (11th Cir. 2018). 2 Case: 19-20066 Document: 00515514095 Page: 3 Date Filed: 08/04/2020 No. 19-20066 Before the Coal Act, a series of National Bituminous Coal Wage Agreements between the United Mine Workers of America (UMWA) and coal companies had resulted in two multiemployer trusts that provided health care benefits to retired miners: the 1950 Benefit Plan and the 1974 Benefit Plan and Trust. These trusts guaranteed lifetime benefits, but they quickly encountered financial difficulties due to rising health care ...
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