Wells Fargo Bank NA v. Madan, 2:11-cv-02061

Wells Fargo lent the Debtors $20,000,000 under a 2006 loan agreement, guaranteed by four Guarantors.
The Debtors defaulted by June 2010 and filed Chapter 11 in the District of Arizona.
Wells Fargo filed a state-court complaint against the Guarantors to recover the debt, which was removed to district court and referred to the Bankruptcy Court as a Guarantor Adversary Proceeding.
The Debtors also filed a separate adversary proceeding in bankruptcy court with identical state-law claims against Wells Fargo.
Bankruptcy Court denied remand of the Guarantor Adversary Proceeding, concluding it had related-to jurisdiction due to the guarantees.
In Oct. 2011 Wells Fargo sought withdrawal of the reference in light of Stern v. Marshall; the court denied the motion in Apr. 2012.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Bankruptcy Court has jurisdiction to hear the matter	Wells Fargo argues related-to jurisdiction exists for Guarantor Adversary Proceeding.	Defendants accept related-to jurisdiction and oppose withdrawal.	Bankruptcy Court had related-to jurisdiction; no withdrawal required at this stage.
Whether cause exists to withdraw the reference under 28 U.S.C. § 157(d)	Withdrawal would promote efficiency and reduce waste of resources.	Referral aids efficiency; Stern does not mandate withdrawal here.	No cause shown to withdraw; reference denied.

Stern v. Marshall, 131 S. Ct. 2594 (2011) (limits finaljudgment authority of bankruptcy courts on certain state-law counterclaims)
In re ACI-HDT Supply Co., 205 B.R. 231 (9th Cir. B.A.P. 1997) (definition of 'related to' jurisdiction and bankruptcy court's role)
In re Canter, 299 F.3d 1150 (9th Cir. 2002) (factors for withdrawing reference: efficiency, delay, uniformity, forum shopping)