Saint Catherine Hospital of Indiana LLC v. Indiana Family and Social Services Admin.

Dist. Ct. erred in reversing Bankruptcy Ct. determination that defendant violated automatic stay provisions by continuing to withhold Medicaid reimbursements from plaintiff to satisfy plaintiff’s obligation to pay Hospital Assessment Fee after plaintiff had filed Chapter 11 bankruptcy petition. Said fee was pre-petition claim under applicable “conduct test,” where calculation of said fee had taken place prior to filing of bankruptcy petition, and thus defendant’s efforts to collect on said fee were subject to automatic stay provisions of Bankruptcy Code. Ct. rejected defendant’s claim that relevant conduct was plaintiff-hospital’s operations that occurred after date of bankruptcy petition.