The district court found "cause" under 28 U.S.C. § 157(d) to permissively withdraw the reference of a non-core adversary proceeding from the bankruptcy court. In so doing, the district court held that cause for permissive withdrawal of the reference is limited to a narrow set of circumstances, the existence of which is determined on the facts presented by each particular case, and withdrawal is generally appropriate when either judicial economy would be served or a party has a right to a jury trial. In the case before it, the non-debtor defendant had a seventh amendment right to a jury trial, which it had timely demanded, and it had not consented to the bankruptcy court's jurisdiction. Reference was therefore withdrawn.

The court determined that it had subject matter jurisdiction to consider a dispute between non-debtors that related to a chapter 11 plan confirmed more than five years prior to the dispute. However, the court concluded, based on the facts before it, that permissive abstention pursuant to 28 U.S.C. § 1334(c)(1) was appropriate. The court recommended to the district court that, in cases involving confirmed chapter 11 plans that are largely completed and resolution of the dispute will have little or no effect on the bankruptcy case, disputes between third parties should not be determined in the bankruptcy court and permissive abstention should be used to transfer such cases back to jurisdictions statutorily designated to handle them.

The district court considered a creditor's motion for change of venue of a bankruptcy case, en banc. The court concluded that the bankruptcy court's practice of automatically transmitting change of venue cases to the district court for disposition was not in keeping with the spirit and interpretation of various statutes, bankruptcy rules, and Local Rule B-106. The court resolved to amend Rule B-106 to provide that motions for change of venue in bankruptcy cases would thereafter be heard initially by the bankruptcy court, which would then provide a report and recommendation on the motion to the district court. In the case before it, the district court granted the motion to change venue in order to avoid further delay.

Trustee for Ponzi scheme debtors asserted fraudulent transfer claims, pursuant to 11 U.S.C. § 548 and 544(b), against defendant, an attorney who acted as debtors' coordinating counsel with respect to numerous lawsuits filed against debtors across the country. Defendant argued that he was essentially a conduit from debtors to local counsel, and that he should not be accountable for money he did not retain. After a trial, the bankruptcy court concluded that defendant had failed to account properly for more than $350,000 of funds that had been transferred to him by debtors, and granted trustee a judgment for that amount. The district court agreed with the bankruptcy court's conclusion that trustee had established that debtors had transferred funds to defendant during the one-year period prior to debtors' bankruptcy filing, and that debtors were insolvent at the time of those transfers. The district court rejected defendant's argument that trustee had failed to meet his burden of proving that debtors received less than reasonably equivalent value for those transfers, on the ground that trustee testified that his investigation found no evidence at all of consideration received by debtors, which placed the duty on defendant to produce evidence of value returned to debtors. As defendant's accounting practices were grossly inadequate, he failed to establish that debtors had received value in return for the transfers made to him. However, the district court ruled that the bankruptcy court had failed to credit defendant with a few transfers that were adequately tied to legal services provided to debtors, totaling approximately $37,000, and affirmed the judgment less that amount.