improperly held in favor of Hanover on independent equitable grounds, which are not recognized as a defense to an avoidance action in bankruptcy. We address each argument in turn. A Earmarking The earmarking defense in bankruptcy is a judicially created exception to the statutory power of the bankruptcy trustee under § 547 to avoid or set aside an otherwise preferential transfer of assets. See McCuskey v. Nat’l Bank of Waterloo (In re Bohlen Enters., Ltd.), 859 F.2d 561, 565 (8th Cir.1988). The earmarking defense applies “[w]hen a third person makes a loan to a debtor specifically to enable that debtor to satisfy the claim of a designated creditor.” 5 Collier on Bankruptcy ¶ 547.03[2][a] (16th ed. 2011); see Va. Nat’l Bank v. Woodson (In re Decker), 329 F.2d 836, 839 (4th Cir.1964) (<HOLDING>). The proceeds of such an “earmarked” loan
holding that specific jurisdiction requires at least butfor causation holding that even when there is a legitimate government purpose the discrimination must bear at least some rational relationship to that purpose holding that effect of discharge of debt under bankruptcy code is the same as it was under the 1898 bankruptcy act it is not an extinguishment of the debt but only a bar to enforcement of the debt as a personal obligation of the debt or holding that a transfer was not an avoidable preference when it was made for the specific purpose of paying at least a portion of a particular debt holding that it was within family courts discretion to assign all debt to one party when court found that party to be at fault for debt