Courts disagree on whether a trustee may recover proceeds of a fraudulent transfer from a later transferee, not only the fraudulently transferred property itself.
Even though subject matter jurisdiction persists when there is no longer an effect on the estate, the court may exercise discretion to dismiss, the Fifth Circuit says.
If the parties litigate but the defendant eventually defaults, the default judgment can result in nondischargeability via issue preclusion, Eleventh Circuit holds.
