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Courts Divided on Venue for Small-Dollar Avoidance Actions

Judges Pappas and Teel permit avoidance actions for small amounts to be prosecuted in the debtors’ bankruptcy courts.
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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.
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Defectively Executed Mortgages Are [Still] Avoidable in Ohio

Sixth Circuit distinguishes between a trustee’s powers as a bona fide purchaser compared to a hypothetical judicial lienholder.
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Creating a Split, Sixth Circuit Holds: No Waiver of Immunity for Indian Tribes

A divided panel of the Sixth Circuit holds that Section 106 does not waive sovereign immunity for Indian tribes.
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