Caribbean Fuels America, Inc. v. Dillworth

Jonathan McHenry — the former landlord of a bankrupt entity and its principals — appeals the bankruptcy court’s entry of judgment against him, after a bench trial, for $74,375. The bankruptcy court determined that McHenry received those funds as a result of a series of constructively fraudulent transfers by debtor Caribbean Fuels America, Inc. (“C-Fuels”). In doing so, the bankruptcy court concluded that C-Fuels did not receive “reasonably equivalent value” under 11 U.S.C. § 548 for monetary transfers made to McHenry under the lease of a house used as both a residence and a home office by…