March 13, 2019 Trustee Gloms Proceeds of an Unperfected Consignment, Not Just the Goods Ninth Circuit interprets UCC § 9-319(a) to permit avoidance of consignor’s interest in proceeds of an unperfected consignment. 9th Circuit , October 13, 2016 Supreme Court’s Upcoming FDCPA Decision Also May Govern RICO Suits California district courts split on whether filing stale claims violates RICO. 9th Circuit , California , California Southern District ,