N1 Creditors Trust v. Crown Packaging Corp. (In re Nukote Intl Inc.)

Ruling: 
Small-dollar home court venue exception applied to non-consumer, non-insider preference proceeding between creditors' trust and corporation.
Procedural posture: 
Plaintiff creditors' trust brought a non-consumer, non-insider preference action under 11 U.S.C.S. § 547(a) against defendant, a corporation that resided in Missouri, for an amount less than $11,725. The Missouri corporation moved to dismiss the preference proceeding for lack of proper venue, arguing that the action could only properly be brought in Missouri, pursuant to 28 U.S.C.S. § 1409(b).
Issue: 
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Commercial case opionion summary, case decided on September 02,2011, LexisNexis #1011-030