In re Hessco Industries, Inc.9th Cir. BAP 2003  ORDINARY COURSE DEFENSE AGAINST PREFERENCE ACTION REQUIRES EVIDENCE OF PREVAILING BUSINESS STANDARD
Court reverses the bankruptcy court's conclusion that the ordinary course of business defense precluded judgment for the Trustee on the preference cause of action because appellees had failed to present evidence of prevailing business standards as required under Sulmeyer v. Suzuki (In re Grand Chevrolet, Inc.), 25 F.3d 728, 732 (9th Cir. 1994).

But the court recited with approval remarks from Ganis Credit Corp. v. Anderson (In re Jan Weilert RV, Inc.), 315 F.3d 1192 (9th Cir. 2003), amended by 326 F.3d 1028 (9th Cir. 2003): “[C]reditors are not required to prove a particular uniform set of business terms, rather "ordinary business terms" refers to the broad range of terms that encompasses the practices employed by those debtors and creditors, including terms that are ordinary for those under financial distress. Only a transaction that is so unusual or uncommon "as to render it an aberration in the relevant industry," falls outside the broad range of terms encompassed by the meaning of "ordinary business terms."

BATLAN v. TRANSAMERICA COMMERCIAL FIN. CORP. (09/13/01 - No. 99-35946) (9^th Cir. Ct App)   Under 11 USC 547(b)(5), a bankruptcy trustee must still prove that a secured creditor received payments in excess of its secured interest during the 90 days before the debtor filed a petition, even if the creditor had a floating lien. http://caselaw.lp.findlaw.com/data2/circs/9th/9935946p.pdf

GANIS CREDIT CORP. v. ANDERSON (01/13/03 - No. 01-55455/56872) (9^th Cir Ct Apps)  Under 11 U.S.C. section 547(c)(2)(C), a court cannot limit "ordinary business terms" to the "average" transactions in the industry, but must consider the broad range of terms that encompasses the practices employed by similarly situated debtors and creditors facing the same or similar problems.  http://caselaw.lp.findlaw.com/data2/circs/9th/0155455p.pdf

FRANK v. MICHIGAN STATE UNEMPLOYMENT AGENCY (06/06/01 - No. 00-1233)  (6th Cir St App)  Pre-petition liens on the bankruptcy debtor's property do not reattach to post-petition preference proceeds recovered by a bankruptcy trustee because the proceeds are property of the estate to be distributed to the debtor's creditors under the Bankruptcy Code. 

MOREHEAD v. STATE FARM MUT. AUTO. INS. CO. (05/03/01 - No. 99-6430)  (6th Cir St App) A wage garnishment is an avoidable transfer where the garnishment is of wages earned during the 90-day preference period in bankruptcy under 11 USC 547(b)(4)(A).  http://laws.lp.findlaw.com/6th/01a0143p.html