Proceedings over which bankruptcy courts may exercise “related to jurisdiction” even when the proceeding is not one that invokes a substantive right provided by the Bankruptcy Code. Non-core jurisdiction is conferred upon bankruptcy courts so long as the proceeding, even if not core, “is otherwise related to a case under title 11.” Such phrase appears broad in scope, leading some courts to exercise “related to” jurisdiction in broad fashion and in turn leading some critics to argue that “related to” jurisdiction is not as expansive as some practitioners and some courts contend.
28 U.S.C. § 157(c)(1). See also Core Proceedings, Jurisdiction.