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Trustees Fraudulent Transfers Debtors

DLA Piper

Ninth Circuit Authorizes Trustees to Avoid Intentional Fraudulent Transfers Without Need to Demonstrate Creditor Harm

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In a case of first impression in the Ninth Circuit, the US Court of Appeals recently handed bankruptcy trustees a significant power by ruling in The Lovering Tubbs Trust v. Hoffman (In re O’Gorman) that a trustee can avoid...more

Gray Reed

Fraud in the Oil Patch the Modern Way

Gray Reed on

Once upon a time a good way to commit oil patch theft was to back a truck up to the tank battery in the middle of the night, fill ‘er up, and drive off into the darkness. In re: Black Elk Energy Offshore Operations LLC shows...more

Patterson Belknap Webb & Tyler LLP

Seventh Circuit Addresses Scope of Section 546(e)

We have previously blogged about the section 546(e) defense to a trustee’s avoidance powers under the Bankruptcy Code. A trustee has broad powers to set aside certain transfers made by debtors before bankruptcy. See 11 U.S.C....more

Dorsey & Whitney LLP

Fifth Circuit Holds Avoidance Actions Can Be Sold

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Joining the Eighth and Ninth Circuit Courts of Appeals, the Fifth Circuit Court of Appeals recently held that a debtor or trustee can sell its avoidance actions to third-party, non-estate representatives. See Briar Capital...more

Jones Day

Business Restructuring Review Vol. 23 No. 1 | January-February 2024

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One year ago, we wrote that 2022 would be remembered in the corporate bankruptcy world for the “crypto winter” that descended in November 2022 with the spectacular collapse of FTX Trading Ltd., Alameda Research, and...more

Jones Day

Second Circuit Adopts "Transfer-by-Transfer" Approach to Bankruptcy Code's Safe Harbor for Securities Contracts Payments

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The scope of the Bankruptcy Code's "safe harbor" shielding certain securities, commodity, or forward-contract payments from avoidance as fraudulent transfers has long been a magnet for controversy, particularly after the U.S....more

Jones Day

New York Bankruptcy Court: Setoff and Unjust Enrichment Cannot Be Asserted as Affirmative Defenses in Bankruptcy Avoidance...

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In a 2021 ruling, the U.S. Court of Appeals for the Second Circuit revived nearly 100 lawsuits seeking to recover fraudulent transfers made as part of the Madoff Ponzi scheme. In one of the latest chapters in that resurrected...more

Jones Day

Delaware Bankruptcy Court Imputes Officer's Fraudulent Intent to Corporation in Avoidance Litigation

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A powerful tool afforded to a bankruptcy trustee or a chapter 11 debtor-in-possession ("DIP") is the power to recover pre-bankruptcy transfers that are avoidable under federal bankruptcy law (or sometimes state law) because...more

Patterson Belknap Webb & Tyler LLP

Tenth Circuit Holds that Sovereign Immunity Does Not Limit Section 544 Claim

Section 544(b)(1) of the Bankruptcy Code enables a trustee to step into the shoes of a creditor and avoid a transfer “of an interest of the debtor in property” that an unsecured creditor could avoid under applicable state...more

Jenner & Block

Recent Developments in Bankruptcy Law, January 2023

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1. AUTOMATIC STAY - 1.1 Covered Activities - 1.1.a Court declines to enjoin third party claims against the debtor’s jointly liable parent corporation. The debtor manufactured earplugs for many years. A major multinational...more

Kelley Drye & Warren LLP

Ten Years Gone – Delaware Bankruptcy Judge Rejects Effort to Extend Lookback Period for Avoidance of Pre-Bankruptcy Transfers

A recent decision by Delaware Bankruptcy Judge John Dorsey will limit the ability of bankruptcy trustees to expand the lookback period for avoiding pre-bankruptcy transfers beyond the four years provided under most state law...more

Fox Rothschild LLP

Not all Forced-Sale Mortgage Foreclosures are Exempt from Avoidance as Fraudulent Transfers Under Section 548 – a Case Study...

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The United States Supreme Court held in BFP v. Resolution Trust, that properties sold at “force-sale” mortgage foreclosure sales properly conducted pursuant to a state’s foreclosure statute are presumed to have been sold for...more

Patterson Belknap Webb & Tyler LLP

One Bankruptcy Court’s Analysis of a Motion to Dismiss Avoidance Claims: The Analytical Framework

A federal judge recently allowed a trustee’s preferential transfer claim against a law firm to proceed but dismissed a constructive fraudulent transfer claim. The decision highlights the pleading standards and analytical...more

Patterson Belknap Webb & Tyler LLP

“Diminishing” Returns: A Pre-Petition Change of Life Insurance Beneficiary is Not Subject to Avoidance as a Fraudulent Transfer

Does a debtor’s pre-petition change of the beneficiary of a life insurance policy constitute a “transfer” of an interest of the debtor in property? Not according to the U.S. Bankruptcy Court for the Eastern District of North...more

Kramer Levin Naftalis & Frankel LLP

Bankruptcy Court Permits Chapter 7 Trustee to Utilize IRS’ Look-Back Period in Seeking to Avoid Fraudulent Transfers

In its recent decision in Mitchell v. Zagaroli, Adv. Pro. No. 20-05000, 2020 WL 6495156 (Bankr. W.D.N.C. Nov. 3, 2020), the Bankruptcy Court for the Western District of North Carolina held that the Chapter 7 trustee could...more

Lowenstein Sandler LLP

Bankruptcy Ruling Highlights Longer Lookback Trend

Projections suggest over 1 million bankruptcy petitions will be filed in 2021. In preparing for those filings, counsel routinely evaluate the prospective creditor pool to determine, inter alia, the types of creditors, claim...more

Patterson Belknap Webb & Tyler LLP

Delaware Bankruptcy Court Issues Decision on Whether a Debtor Can Be a “Financial Participant”

We have blogged previously about section 546(e), the Bankruptcy Code’s safe harbor for certain transfers otherwise subject to avoidance as preferences or fraudulent transfers. See 11 U.S.C. § 546(e). Among the transfers...more

Rosenberg Martin Greenberg LLP

The Trustee Is Suing Me For A Transfer I Received How Many Years Ago?

Any creditor that has experienced more than a few customers or borrowers filing for bankruptcy is aware that there is a risk of being sued by a trustee to avoid transfers that the creditor received prior to the bankruptcy...more

Husch Blackwell LLP

First Circuit Clarifies When College Tuition Can Be Considered A Fraudulent Transfer

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Last month the First Circuit Court of Appeals became the first federal appellate court to take up the matter of whether college tuition paid for an adult child by a bankrupt parent constitutes a fraudulent transfer. Chief...more

Patterson Belknap Webb & Tyler LLP

Bankruptcy Court Addresses Standard For Recovery Of An Alleged Fraudulent Transfer From A Subsequent Transferee

The Bankruptcy Code gives a trustee powers to avoid certain pre-bankruptcy transfers of the debtor’s property to other entities. For example, a trustee can avoid transfers made with the intent to impair the ability of...more

Mintz - Bankruptcy & Restructuring Viewpoints

Decade Old Transactions Potentially Subject to Bankruptcy Clawback in Massachusetts

Transfers and transactions up to ten years old may be scrutinized, unwound and recovered by a trustee, the bankruptcy court sitting in Massachusetts recently held in the NECCO (think chalky wafer candy) bankruptcy case. The...more

Patterson Belknap Webb & Tyler LLP

When Has A Trustee Exhausted His Section 550 “Single Satisfaction”?

A bankruptcy trustee exercising her or his avoidance powers under Chapter 5 of the Bankruptcy Code may seek to recover the avoidably transferred property (or its value) from “the initial transferee,” “the entity for whose...more

Jones Day

Tribune District Court Rules That LBO Payments May Not Be Avoided Because Debtor Was "Customer" of "Financial Institution"

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In In re Tribune Co. Fraudulent Conveyance Litig., 2019 WL 1771786 (S.D.N.Y. Apr. 23, 2019), the U.S. District Court for the Southern District of New York denied a litigation trustee’s motion to amend a complaint seeking to...more

Skadden, Arps, Slate, Meagher & Flom LLP

Second Circuit Allows Avoidance Actions Against Foreign Transferees in Madoff Proceeding

On February 25, 2019, the U.S. Court of Appeals for the Second Circuit vacated the bankruptcy court’s dismissal of avoidance actions brought by Irving Picard, the trustee (Trustee) for the liquidation of Bernard L. Madoff...more

Mintz - Bankruptcy & Restructuring Viewpoints

The Delaware Bankruptcy Court Grapples With Section 546(e) Post-Merit Management

In its ruling in FTI Consulting, Inc. v. Sweeney (In re Centaur, LLC), the United States Bankruptcy Court for the District of Delaware addressed the Supreme Court’s recent clarification of the scope of Bankruptcy Code Section...more

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