Rochelle's Daily Wire

The Second Circuit split with the First Circuit, which had permitted nationwide class actions because the discharge injunction is statutory.

Reversing in favor of the Madoff trustee, the Second Circuit rules that inquiry notice, not willful blindness, governs the good faith defense by recipients of fraudulent transfers.

Neither comity nor the presumption against extraterritorial application of U.S. statutes bars trustees from suing to recover subsequent transfers made abroad.

Tronox spans more law, this time on finality regarding injunctions.