Campbell v. The Hanover Insurance Company
Petition for certiorari denied on October 7, 2013
Issue: (1) Whether a party asserting a “new value” defense
to a preference claim pursuant to 11 U.S.C. §
547(c)(1) must prove the specific value “in money or
money’s worth” of the assets transferred to the
debtor, as the Third, Fifth, Ninth, Tenth and
Eleventh Circuits have held, or a mere
approximation of value, as the Fourth Circuit below
and the Eighth Circuit, as well as inconsistent Third
and Tenth Circuit decisions, have held.
