Skip to main content

§ 547(c)

US Bank Natl Assn v. Petro Commer. Servs. (In re Interstate Bakeries Corp.)

Ruling
Ordinary course of business defense failed due to failure of testimony to provide objective evidence of payment practices in honey brokerage industry.
Procedural posture

Plaintiff trustee filed an adversary proceeding against defendants creditor seeking to recover a portion of $412,240 in allegedly preferential transfers that the debtor made to the creditor in the 90 days before the debtor's bankruptcy petition date. The matter proceeded to trial on the creditor's former 11 U.S.C.S. § 547(c)(2) and (c)(4) defenses.

ABI Membership is required to access the full summary of US Bank Natl Assn v. Petro Commer. Servs. (In re Interstate Bakeries Corp.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on June 17, 2013 , LexisNexis #0713-057

Giuliano v. RPG Mgmt. (In re NWL Holdings Inc.)

Ruling
Transfers made to ensure continuation of insurance coverage were contemporaneous exchanges for new value and not avoidable.
Procedural posture

Chapter 7 trustee filed a complaint against defendant creditor seeking to avoid and recover certain payments as preferential and fraudulent transfers under 11 U.S.C.S. § 547. The creditor filed a motion for summary judgment. The trustee contested the motion. The court issued its findings of fact and conclusions of law.

ABI Membership is required to access the full summary of Giuliano v. RPG Mgmt. (In re NWL Holdings Inc.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on June 04, 2013 , LexisNexis #0713-094

Davis v. All Points Packaging & Distrib. (In re Quebeqcor World (USA) Inc.)

Ruling
Payment made beyond pre-preference period average was not made in ordinary course of business and was avoidable.
Procedural posture

Litigation trustee under bankruptcy debtors' plan brought an adversary proceeding against defendant transferee of funds from the debtors alleging that a payment to the transferee was avoidable as a preferential transfer, and the transferee asserted that the payment was made in the ordinary course of business and was thus not avoidable under 11 U.S.C.S. § 547(c)(2). The trustee and the transferee cross-moved for summary judgment.

ABI Membership is required to access the full summary of Davis v. All Points Packaging & Distrib. (In re Quebeqcor World (USA) Inc.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on April 22, 2013 , LexisNexis #0513-058

Kapila v. Spiegel LLC (In re Fountainebleau Las Vegas Holdings LLC)

Ruling
Payments for work performed prior to preference period were not avoidable.
Procedural posture

Plaintiff trustee filed a complaint against defendant seeking to avoid and recover an alleged preferential transfer pursuant to 11 U.S.C.S. § 547. Defendant filed a motion for summary judgment.

ABI Membership is required to access the full summary of Kapila v. Spiegel LLC (In re Fountainebleau Las Vegas Holdings LLC) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on April 12, 2013 , LexisNexis #0513-018

Rushton v. SMC Elec. Prods. (In re C.W. Mining Co.)

Ruling
Preference period payment by debtor mining company to purchase electrical system was made in ordinary course of business and was not avoidable.
Procedural posture

Chapter 7 trustee's complaint sought relief pursuant to 11 U.S.C.S. §§ 547, 548 against defendants. Defendants moved for summary judgment.

ABI Membership is required to access the full summary of Rushton v. SMC Elec. Prods. (In re C.W. Mining Co.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on March 15, 2013 , LexisNexis #0413-088

Goodman v. Triple C Marine Salvage Inc. (In re Gulf Fleet Holdings Inc.)

Ruling
Preference period payments for one time transaction were not made in ordinary course of business and could be avoided.
Procedural posture

In a preference action brought by chapter 11 trustee under 11 U.S.C.S. § 547 against defendant supplier, the supplier raised an ordinary course defense under § 547(c)(2).

ABI Membership is required to access the full summary of Goodman v. Triple C Marine Salvage Inc. (In re Gulf Fleet Holdings Inc.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on March 12, 2013 , LexisNexis #0413-020

Wallach v. Ford Motor Co. (In re Performance Transp. Servs.)

Ruling
New value defense did not apply where parties engaged in preferential payments rather than available setoff.
Procedural posture

Plaintiff chapter 7 trustee sought to recover payments made to defendant creditor as preferential, but the creditor, contending that the payments were for new value under 11 U.S.C.S. § 547(c)(4), filed a motion for summary judgment.

ABI Membership is required to access the full summary of Wallach v. Ford Motor Co. (In re Performance Transp. Servs.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on February 08, 2013 , LexisNexis #0313-053

Hopkins v. Marble (In re Kempkers)

Ruling
Transferee not entitled to attorneys' fees for successful defense of preference proceeding.
Procedural posture

After the court granted summary judgment in favor of defendant transferee in chapter 7 trustee's action to recover an avoidable preference, the transferee filed a motion for an award of attorneys fees and costs incurred in defending against that claim.

ABI Membership is required to access the full summary of Hopkins v. Marble (In re Kempkers) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on February 04, 2013 , LexisNexis #0213-128

Velde v. Border State Bank (In re HovdeBray Enters.)

Ruling
Liquidation sale proceeds properly avoided as preference as floating lien, ordinary course of business and new value defenses did not apply.
Procedural posture

Appellant bank challenged rulings of the U.S. Bankruptcy Court for the District of Minnesota denying summary judgment on appellee trustee's preference action per 11 U.S.C.S. § 547 on findings that its lien was perfected within the § 547 perfection period, that its § 547(c)(5) "floating lien" defense to a security interest perfected during the preference period lacked merit, and that the trustee, who had cross-appealed, was to recover $242,824.

ABI Membership is required to access the full summary of Velde v. Border State Bank (In re HovdeBray Enters.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on December 03, 2012 , LexisNexis #1212-124

In re Prevalence Health LLC

Ruling
Transfer to debtor's president and chief operating officer avoided as preferential given inability to establish ordinary course of business exception.
Procedural posture

The chapter 11 trustee filed an action against defendant the president and chief operating officer of the debtor, to set aside a payment as a preference pursuant to 11 U.S.C.S. § 547. Defendant argued that the transfer was not a preference because it was made in the ordinary course of the debtor's business under § 547(c)(2). Both parties filed motions for summary judgment.

ABI Membership is required to access the full summary of In re Prevalence Health LLC Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on November 07, 2012 , LexisNexis #1212-024