National Union Fire Insurance Company of Pittsburgh, PA v. DiMucci

A bankruptcy court default judgment on a state-law claim for fraudulent transfer of funds from a bankruptcy claim after the claim process is not a final judgment by a court of competent jurisdiction.Court properly entered summary judgment for mortgagor's subrogee on its claim for unjust enrichment, as there was no evidence to controvert defendant's mortgagor's right to funds. Court properly entered summary judgment in granting a constructive trust was proper, where a check was mistakenly sent to Defendant's LLC and then Defendant refused to return those funds. Court properly awarded prejudgment interest, where Defendant knew the funds were the subject of a default judgment, a stipulation,and an assignment of rents. (LAVIN, concurring; MASON, specially concurring.)