The record
The Third Circuit dismissed Johnson & Johnson subsidiary LTL Management's first Chapter 11 petition, holding that only a debtor in financial distress may access Chapter 11 and that LTL was not in financial distress.
Claim scope
A published federal appellate holding that LTL's Chapter 11 filing failed the good-faith requirement of 11 U.S.C. 1112(b) for want of financial distress; the court reversed the Bankruptcy Court's denial of the motions to dismiss and remanded with instruction to dismiss.
What this source does not establish
It does not hold that talc products contained asbestos, that they cause disease, or that the divisional merger was fraudulent. The court expressly declined the pejorative framing, writing that it would 'more benignly call it a divisional merger.' Dismissal was on bankruptcy eligibility grounds only.
Limitations
Reporter citation resolved indirectly: CourtListener's citation index has an EMPTY citations field for clusters 9371539/9371929/9388617. The cite 64 F.4th 84 was confirmed by two independent PUBLISHED Fourth Circuit opinions printing it verbatim — Bestwall LLC v. Official Committee of Asbestos Claimants, 71 F.4th 168 (4th Cir. 2023) at cluster 9408506, and Bestwall LLC v. Official Committee (4th Cir. Aug. 1, 2025), cluster 10646900. A direct citation-lookup POST for '64 F.4th 84' returned status 404.
Source
Case Citation — In re LTL Mgmt., LLC, 64 F.4th 84 (3d Cir. 2023)