In 1994, in BPF v. Resolution Trust Corporation, the U.S. Supreme Court considered whether a regularly conducted, non-collusive, non-judicial foreclosure sale could be challenged as a fraudulent conveyance in a bankruptcy proceeding.  In addition to its holding on the specific issue presented, the opinion offers an informative discussion of the nature and purposes of non-judicial foreclosure sales and a fascinating debate about the "plain language" technique of statutory construction..