The purpose behind disallowing voluntary transfers of property made by the debtor from the exemption under section 522(g) is to prevent the debtor from receiving a windfall which would enable him to benefit from his own voluntary act. In re Via, 107 B.R. 91, 94 (Bankr.W.D.Va. 1989). Following the example given by the legislative history, courts have determined that an involuntary transfer occurs when the property is transferred by operation of law, such as by means of an execution of judgment, repossession, or garnishment.

’ " In re Hill , 566 B.R. at 894 (citations omitted). See alsoVia v. Colonial Am. Nat'l Bank (In re Via) , 107 B.R. 91 (Bankr. W.D. Va. 1989) (concluding that payment made in response to legal coercion is not voluntary, issuance of garnishment summons resulted in debtor making coerced payments due to threat of losing her wages and the inherent threat to her employment through legal compulsion). In Via , the garnishment was the result of a legal judgment, and noncompliance (if possible) could mean loss of employment.

Other courts have similarly found transfers to be involuntary where they occurred by operation of law. See In re Yarber , 522 B.R. 328, 330 (Bankr. D. Or. 2014) (transfer of bail bond deposit to prevent incarceration was involuntary); Maus v. Joint Twp. Dist. Memorial Hospital (In re Maus) , 282 B.R. 836, 838 (Bankr. N.D. Ohio 2002) (garnishment constituted involuntary transfer); Via v. Colonial Am. Nat'l Bank (In re Via) , 107 B.R. 91, 94–95 (Bankr. W.D. Va. 1989) (loan obtained and used to satisfy creditor to prevent garnishment was involuntary); see also Seidel v. First Nat'l Bank of Palmerton (In re Seidel) , 27 B.R. 347, 352 (Bankr. E.D. Pa. 1983) (transfer involuntary where critical facts concealed from debtor).In addition, courts have generally agreed that even consensual transfers may be involuntary if they involve fraud, duress, material representation or coercion, among other things.

12[2] [b], at 522–114 (Alan N. Resnick & Henry J. Sommer eds., 16th ed. 2014). See, e.g., Via v. Colonial American Nat'l Bank (In re Via), 107 B.R. 91, 94–95 (Bankr.W.D.Va.1989) (transfer involuntary where debtor responded to a garnishment notice by obtaining a loan to pay the creditor in order to avoid garnishment). Comparing the threat of garnishment to the threat of incarceration, if anything, the essential involuntariness of the transfer in this case is even stronger than in In re Via.

); In re Djerf, 188 B.R. at 588 (“Courts interpreting the exception embodied in § 547(c)(8) ... have generally concluded that its design is to permit a relatively small in dollar amount or a nominal prepetition transfer to a consumer creditor to withstand attack under § 547(b) notwithstanding its preferential effect.”); Via v. Colonial Am. Nat'l Bank (In re Via), 107 B.R. 91, 95 (Bankr.W.D.Va.1989) (finding § 547(c)(8) does not provide a $600 “safe harbor” every time a transfer is made, and that, “in light of the [statute's] clear wording,” transfers greater than $600 are entirely avoidable); Johnson v. Ford Motor Credit Co. (In re Johnson), 53 B.R. 919, 921 (Bankr.N.D.Ill.1985) (“[Section 547(c)(8)'s] language clearly and unambiguously expresses Congress's intent to permit relatively small transfers of the debtor's property before the filing of the bankruptcy petition to stand regardless of whether they have the effect of preferring one creditor over another.”). Section 547(c)(8) is not implicated in this appeal.

DISCUSSION This Court adopts the reasoning and conclusions of the Decisions of the Bankruptcy Courts in In re Via, 107 B.R. 91 (Bankr. W.D.Va. 1989) and In re Vickery, 63 B.R. 222 (Bankr. E.D.Tenn. 1986). In a consumer debtor case, once the amount of a transfer or series of transfers to a creditor within ninety days before the filing of the petition exceeds $599.99, the entire transfer or series of transfers is avoidable if the requirements of Section 547(b) are otherwise met.

See Matter of Hailes, 77 F.3d 873 (5th Cir. 1996); In re Djerf, 188 B.R. 586 (Bankr. D. Minn. 1995). If the threshold is reached, the trustee is entitled to recover the entire amount transferred, not just the amount in excess of $600.00. See In re Yetter, 112 B.R. 301 (Bankr. S.D. Iowa 1990); In re Via, 107 B.R. 91 (Bankr. W.D. Va. 1989). Discussion.