Circuit Court of Appeals Cases from Last Week

2nd Circuit Court of Appeals, January 22, 2010
In re: Jackson, --- F.3d ---, 2010 WL --------- (2nd Cir. 2010)(settlement payment not exempt, "future earnings" under tort law was unpersuasive given the different purposes of tort law and bankruptcy law) 

4th Circuit Court of Appeals, January 22, 2010
United Rentals, Inc. v. Angell, --- F.3d ---, 2010 WL --------- (4th Cir. 2010)(payments here are an avoidable preference regardless of whether the transfers set in motion a chain of events that resulted in the debtor's recoupment of the amounts paid, no showing that such new value was given to the debtor as part of a contemporaneous exchange)