Enrica Brook
St. John’s University School of Law
American Bankruptcy Institute Law Review Staff
In Pitman Farms v. ARKK Food Co., LLC, the United States Court of Appeals for the Eighth Circuit held that avoidance actions, under chapter 5 of title 11 of the United States Code (the “Bankruptcy Code”), are property of the estate under Section 541(a) that a trustee may sell “free and clear.”[1]