In late December 2025, two senior living facilities filed for Bankruptcy Court protection in the wake of state court actions that had voided certain leases and required the facilities to “turn over resident receipts” to a court-ordered receiver. The Pennsylvania based operating facilities are known as Whitehall Manor, Inc. and Saucon Valley Manor, Inc. The Chapter 11 filings in the Eastern District triggered the automatic stay and made it possible to keep the facilities operating while the debtors seek to negotiate new financing terms and resolve litigation with a secured creditor.

The filings are reported to occur in communities with a total of approximately 324 residents, “including 90 in memory care” units. It can be important to recognize that in Pennsylvania (and in many states), “personal care homes” are required to be licensed by the State, and they are subject to inspection by the Pennsylvania Dept. of Human Services.

The “trust” company and “operating company” structure of these facilities has been described as common in the healthcare industries; in this instance, all four entities are described as “for profit” in nature.

One challenge for potential residents and their families in evaluating the solvency of personal care homes before admission, especially those that are for-profit in nature, is the absence of public records, such as 990 reports made by nonprofit care facilities to the IRS on an annual basis. The fact that all four components of these two facilities are filing the bankruptcy court actions could raise interesting issues for use of assets for payment of creditors.

Such bankruptcy court actions appear to be another example of a rising national trend among “senior living and care” bankruptcies in 2025. Hospital bankruptcies also rose in 2025, even as the “overall health care sector” actually saw a decrease in bankruptcy filings for a second consecutive year, according to reports such as “Senior Living and Care Bankruptcies Climb as Most Healthcare Sectors See Decline,” by McKnights Senior Living News , citing statistics from Gibbins Advisors, a healthcare restructuring advisory firm.

Photo of Katherine C. Pearson Katherine C. Pearson

Katherine C. Pearson is a Professor of Law and the Arthur L. and Sandra S. Piccone Faculty Scholar at Penn State Dickinson Law in Carlisle, Pennsylvania.

Her scholarship focuses on laws and policies connected to aging and she has frequently included age-related issues…

Katherine C. Pearson is a Professor of Law and the Arthur L. and Sandra S. Piccone Faculty Scholar at Penn State Dickinson Law in Carlisle, Pennsylvania.

Her scholarship focuses on laws and policies connected to aging and she has frequently included age-related issues in her teaching of courses on contract law, conflicts of law and nonprofit organizations law.  She is a regular speaker for continuing education programs, both for consumers and lawyers, to address cutting edge concerns in consumer protection for older adults.  She is the author of articles and chapters on access to justice, senior living options including continuing care and life plan communities, long-term care financing and filial obligations, and is the co-author of a treatise, The Law of Financial Abuse and Exploitation (Bisel 2011).

She authored chapters for the Research Handbook on Law, Society and Ageing, published in 2024 as part of a series on law and society handbooks offered by international publisher Edward Elgar. She is a 2024-2025 Fulbright Scholar in Canada and was in residence at the University of Ottawa in the Fall of 2024 as the Research Chair in Health Law, Policy and Ethics.  Her earlier experience as a U.S. Fulbright Scholar (based at the Queen’s University Belfast, Northern Ireland, and working in Ireland, Portugal, and the U.K. in 2009-10), resulted in publications, including an article with an international, historical perspective on ethical concerns for attorneys representing older adults, entitled “The Lesson of the Irish Family Pub,” published by Stetson Law Review.