State Compensation Insurance Fund v. Zamora

Issue: (1) Whether the policy against federal interference with state criminal prosecutions similarly precludes a finding that state criminal restitution payments can be preferences under 11 U.S.C. § 547(b); (2) whether criminal restitution, which is ordered to further the state's goals of deterrence and rehabilitation, is “to or for the benefit of a creditor”? under 11 U.S.C. § 547(b).