Trustee Randall L. Seaver appeals the January 19, 2011 summary judgment of the bankruptcy court in favor of New Buffalo Auto Sales, LLC, Maurice J. Wagener, and Palladium Holdings, LLC.
The bankruptcy court correctly concluded judgment holders pre-petition judgments did not constitute avoidable pre-petition transfers under Bankruptcy Code Section 547(b). Bankruptcy court erred in concluding the judgment holders’ post-petition registration of their judgments and the creation of judgment liens were not avoidable post-petition transfers of property under Section 549(a). Bankruptcy court failed to fully assess whether the bankruptcy estate is entitled to recovery under Section 550(a).
Remanded.
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