Memorandum Opinion Granting Motion to Dismiss for Improper Venue in the United States Bankruptcy Court for the Middle District of Tennessee by U.S. Bankruptcy Judge Keith M. Lundin – Rejecting the reasoning of two other bankruptcy courts in the Sixth Circuit, Middle District of Tennessee U.S. Bankruptcy Judge Lundin concludes: “These avoidance actions ‘arise in’ a case under Title 11. The small dollar venue exception in 28 U.S.C. § 1409(b) applies.” The opinion provides both a reasoned, statutory construction yielding this result and an scholarly, exhaustive treatment of the legislative history of § 1409 beginning with the Bankruptcy Reform Act of 1978. Click here to see a note on this opinion. To see a complete discussion on the use of the “venue defense” see: $11,725 (Pre-April 1, 2010 $10,950) Threshold for Bankruptcy Preference Venue Impediment to Claims.