Generation Res. Holding Co., LLC, 964 F.3d 958 (10th Cir. July 10, 2020)

The Tenth Circuit concluded that the defendant law firms were not “transferees” under the fraudulent transfer statute in bankruptcy, 11 U.S.C. § 550, and therefore the trustee was not entitled to recover fees that the law firms earned through a contingent fee arrangement with the debtor to recover unpaid contract amounts.