Attorney Liability for Fraudulent Transfers
In most states, a creditor cannot sue the lawyer who helped a debtor make a fraudulent transfer unless the lawyer ended up with some of the property.
The fraudulent transfer act, which nearly every state has adopted in one form or another, lets a creditor undo the transfer and recover from the person who received the property. It gives no damages claim against someone who received nothing.
A lawyer who advised the transfer and drafted the documents but took nothing is not a defendant the statute names. Florida’s Supreme Court said so in Freeman v. First Union, and every other state court to consider the question has agreed. Only Colorado’s statute reaches someone who received nothing, in a clause no court has applied to a lawyer.
The creditor’s other route is a claim for civil conspiracy or aiding and abetting, on proof that the lawyer knowingly joined a transfer made to defraud. Eight states allow that claim, each on its own conditions. Eight have refused it. The rest have not decided, Florida among them. The chart below gives each state’s answer and the decision behind it.
Where the claim is allowed, the lawyers who lost, or were sent to trial, had all done something beyond advising and drafting.
- One took the debtor’s stock as security for his own fees.
- One took a deed to the property.
- Two filed agreed judgments that carried out the transfer.
- One told the creditor’s lawyer there was equity in property the debtor no longer owned.
- One paid a $500,000 settlement out of his trust account the day it arrived, with a judgment outstanding.
No court anywhere has held a lawyer liable to a creditor for advice or drafting alone.
Money in the lawyer’s trust account is the hardest case. Under the state acts and in most federal circuits, a lawyer who passes the money through on the debtor’s instructions is a conduit, not a transferee. In the Eleventh Circuit, which covers Florida, the lawyer is the transferee unless the lawyer proves both a lack of control over the money and good faith.
Everywhere, a fee kept out of the money is a transfer to the lawyer, tested on value and good faith.
Whether the transfer is also a crime, and whether the lawyer can be prosecuted for it, is a separate question, answered state by state on the criminal liability page.
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Cases Against Lawyers
The table lists the court decisions, state and federal, in which a lawyer was pursued over a debtor’s transfer or bankruptcy: what the lawyer did, the theory, and how each case ended.
| Case | State and year | What the lawyer did | Theory | Outcome |
|---|---|---|---|---|
| Cadle v. Woods & Erickson | Nevada, 2015 | Created an asset protection trust and entities the debtor then funded | Conspiracy, aiding and abetting, concert of action | No claim against a non-transferee; judgment for the firm affirmed en banc |
| Magnum Steel v. Roderick Linton Belfance | Ohio, 2015 | Advised that any sale be at fair market value; was paid fees for the defense | The act, conspiracy, aiding and abetting | The act reaches only transferor and transferee; fees bona fide; conspiracy failed on the evidence |
| Nastro v. D’Onofrio | Connecticut (federal court), 2003 | Prepared the documents creating an offshore trust | Damages under the act; aiding a fraudulent transfer | Count dismissed on the pleadings |
| Optional Capital v. Akin Gump | California, 2017 | Represented the transferee in the litigation and a mediation | Conspiracy, aiding and abetting | Claims struck under the anti-SLAPP statute; litigation privilege |
| Janssen v. Lommen Abdo | Minnesota, 2014 and 2024 (nonprecedential) | Drafted the entity and transfer papers mid-trial; took $500,000 in mortgages for fees | The act, conspiracy, aiding and abetting | Reinstated at the pleading stage; creditor lost at trial |
| Both v. Frantz | Georgia, 2006 | Drafted powers of attorney and formed the partnership that took the property of the woman he represented | Fraudulent conveyance and conspiracy, brought by that woman | Denial of summary judgment affirmed |
| La Bella Dona v. Belle Femme | Virginia, 2017 | Took a note secured by the debtor’s assets, foreclosed, bought at its own auction, and sold to the family’s new company | Common-law and statutory conspiracy; avoidance | Conspiracy counts dismissed; the conveyance count against the firm as recipient sent back for trial |
| McElhanon v. Hing | Arizona, 1985, approved 1986 | Prepared the stock sale the day after the judgment and kept the certificates as security for his fees | Conspiracy to commit a fraudulent conveyance | $286,120 verdict upheld |
| Nisenzon v. Sadowski | Rhode Island, 1997 | Took the property by quitclaim deed for a consideration the court disbelieved | Fraudulent transfer; fraud | $30,000 judgment affirmed against him as first transferee |
| Essex Crane v. Carter | Texas, 2012 | After the creditor’s judgments, drafted the assignment and agreed judgments for the son’s new company and filed them | Conspiracy; attorney immunity claimed | Summary judgment for the lawyers reversed; fact issues |
| Banco Popular v. Gandi | New Jersey, 2005 | Assisted the transfer and issued an opinion letter to the lender | Conspiracy to violate the act; fraud; negligence | Conspiracy count reinstated at the pleading stage; opinion-letter claims went forward |
| Chapman Lumber v. Tager | Connecticut, 2008 | Advised the debtor to take his name off the deeds, then negotiated a note and mortgage on property the debtor no longer owned | Fraud | $55,500 verdict reinstated with exemplary damages |
| Joel v. Weber | New York, 1993 | Took a $75,000 fee from an insolvent payor | Fraudulent conveyance of the fee; aiding and abetting | Triable issue on the fee |
| PHI Financial v. Johnston Law Office | North Dakota, 2016 | Passed $20,400 through its trust account on instruction and kept $150,000 as fees | The act; first transferee | Conduit as to the pass-through; $115,000 of the fees voided |
| Timothy v. Pia, Anderson | Utah, 2019 (trial-level ruling; appeal vacated) | Held $50,000 of the debtors’ money in its trust account | The act; transferee | Trial court held it no transferee; the appellate affirmance was vacated as moot |
| Trizechahn Gateway v. Schnader Harrison | Pennsylvania, 2023 | Was paid fees by the debtors to handle their appeal | The act; the fee transfers | Judgment for the firm; reasonably equivalent value |
| In re Harwell | Eleventh Circuit, 2010 | Took $500,000 of the debtor’s settlement into his trust account and paid it out the same day | Section 550, initial transferee | Summary judgment for the lawyer reversed; lost on good faith on remand |
| In re Cargo Transportation Services | Bankruptcy court, Florida, 2013 | Took six $5,000 payments into trust, paid its approved fee, and remitted the balance | Section 550, preference | Mere conduit acting in good faith |
| In re Coutee | Fifth Circuit, 1993 | Deposited the debtors’ judgment proceeds in its trust account and paid their bank loan | Section 550, preference | Initial transferee was the bank; the firm was not |
| Southmark v. Schulte Roth & Zabel | Fifth Circuit, 2000 (unpublished) | Took a fee traced to an avoided $3,000,000 transfer | Section 550(b)(1), subsequent transferee | Fee recovered; the firm knew facts making the transfer recoverable |
| In re Bressman | Third Circuit, 2003 | Three firms took $392,218.57 in fees paid by the debtor’s wife | Sections 549 and 550(b)(1) | Firms kept the fees; good faith and no knowledge |
| Rajala v. Spencer Fane | Tenth Circuit, 2020 | Firms were paid from the proceeds of an avoided transfer | Section 550, transferee | Not transferees of the property transferred; complaints dismissed |
| Klein v. King & King & Jones | Tenth Circuit, 2014 (unpublished) | Took a $25,000 defense fee wired from the debtor’s account | Utah act, read with section 550 | Initial transferee; lost on reasonably equivalent value |
| In re Bella Vista by Paramont (Farrar) | Ninth Circuit, 2013 (unpublished) | Debtor’s own counsel, paid from debtor funds | Section 550, initial transferee | Held the initial transferee; no credible argument otherwise |
| DuVoisin v. Kennerly | Federal district court, Tennessee, 1990 | Held the debtor’s money in its escrow account under written instructions | Sections 547, 548, and 550 | Transferee; good faith failed; liability limited to $359,101.60 |
| Boyer v. Carlton, Fields | Seventh Circuit, 1996 | Received $125,000 of the debtor’s money and deducted a $14,000 fee | Section 542 turnover | Transferee of the fee only; ordered to turn over the whole $125,000 as possessor |
| In re Belmonte | Second Circuit, 2019 | Received $59,432 of the debtor’s money | Section 550 | Ordered to remit; no conduit argument made |
| United States v. Webster | Seventh Circuit, 1997 | Incorporated the debtors’ bar, backdated the stock certificates, and drafted false schedules | 18 U.S.C. § 152(1), aiding and abetting | Conviction affirmed |
| United States v. Ledée | First Circuit, 2014 | Drafted the deed nine months before the petition and signed it as president of the corporation | § 152(7) and § 371 | Conviction and 36-month sentence affirmed |
| United States v. Kowalski | Seventh Circuit, 2024 | Concealed about $357,000 of her brother’s money in her own trust account | § 152(1) | Guilty plea; 37-month sentence affirmed |
| United States v. Gellene | Seventh Circuit, 1999 | Filed sworn declarations omitting his firm’s ties to the senior creditor | § 152(3) | Conviction affirmed; 15 months |
| United States v. Knight | Eighth Circuit, 2015 | Advised forming an entity and ran about $1.2 million through his trust account | §§ 152(7), 152(3), 371; aiding and abetting | New trial on every count affirmed; indictment then dismissed |
The Fifty-State Chart
The chart answers three questions for each state. The first is whether the state’s fraudulent transfer act itself gives a claim against a lawyer who received nothing. The second is whether the state allows a claim against that lawyer for aiding and abetting or civil conspiracy. The third is when a lawyer who holds the money becomes a transferee. Each cell names the decision or statute behind it.
Current as of September 2026. Download the attorney liability by state chart (PDF).
“Under the state’s act” means a claim for damages or other relief that the state’s fraudulent transfer statute itself gives against a person who assisted the transfer and never received the property. Some cells rest on a federal court’s reading of the state’s law; they appear where no appellate decision of that state answers the question. The PDF adds each state’s act, the twelve federal circuits’ tests, and the sources for every row.
| State | Under the state’s act | Aiding and abetting | Civil conspiracy | When the lawyer holds the money |
|---|---|---|---|---|
| Alabama | No. The act reaches only the debtor’s own transfer; the court refused to extend it to a third party who controlled the debtor’s assets (Folmar, 2000) | No appellate decision located | No, for a count that rests on the act (Folmar, 2000). Alabama recognizes damages for a conspiracy to defraud arising from a fraudulent conveyance, but every party held liable received or controlled the property (Johns, 2001) | No appellate decision located |
| Alaska | No. The statute only voids the conveyance and gives no damages remedy (Summers, 1993) | Barred by statute for a trust carrying an Alaska transfer restriction, against the trustee and anyone who prepared or funded the trust (AS 34.40.110(e), 1998; no court has construed it). Otherwise no appellate decision located | Yes, as the court stated the rule: a judgment creditor who proves actual fraud and an inadequate statutory remedy may recover damages from a participant in the scheme (Summers, 1993; the defendant was a grantee). Barred by statute for a qualifying Alaska trust (AS 34.40.110(e)) | No appellate decision located |
| Arizona | No. Every remedy in the act runs against the transferee or the transferred asset, and the catch-all supplies no aiding-and-abetting claim (Warne Investments v. Higgins, 2008); the damages claim against a helper lives outside the act, in conspiracy (McElhanon, 1985) | No appellate decision located on a claim for a fraudulent transfer; the act itself supplies none (Warne Investments v. Higgins, 2008) | Yes, against the debtor’s lawyer: a jury verdict the Supreme Court approved (McElhanon, 1985, approved 1986). The creditor must hold a judgment, prove actual fraud, and show the act’s remedies inadequate; drafting alone is not enough | No appellate decision located |
| Arkansas | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| California | No direct claim. A stranger to the transfer is neither the debtor nor the person for whose benefit it was made (Optronic, 2025), and recovery under the act runs only against the transferee classes (§ 3439.08(b)(2)); a conspiracy or aiding claim may still be pleaded on the act | Yes, at the pleading stage, against the debtor’s son who signed the deeds as attorney-in-fact and received nothing (Aghaian, 2020; Berger, 2019). The underlying fraud must be pleaded with particularity | Yes, at the pleading stage (Berger, 2019; Optronic, 2025). Against the debtor’s lawyer the claim must first clear § 1714.10, and a claim aimed only at litigation conduct fails under the litigation privilege and the anti-SLAPP statute (Optional Capital, 2017); a claim aimed at the transfer itself does not (Aghaian, 2020) | No appellate decision located |
| Colorado | Yes, by statute: a judgment for one and one-half the asset’s value or the claim, whichever is less, against a person other than the debtor who acts with an actual intent to hinder, delay, or defraud (C.R.S. § 38-8-108(1)(c), added 2014). No decision applies it to an adviser | No appellate decision located | Yes. A transfer that violates the act is a legal wrong that supports a conspiracy claim, no lien required, with damages independent of the act (Double Oak, 2003). The defendants were the debtor’s alter egos and the transferee | No appellate decision located |
| Connecticut | Federal court’s reading only (Nastro, D. Conn. 2003): a damages claim against the debtor’s lawyer and firm for preparing the trust documents was dismissed, on Connecticut’s policy against lawyer liability to third parties. No Connecticut appellate decision | Federal court’s reading only (Nastro, D. Conn. 2003), on the same ground. No Connecticut appellate decision | Yes, where the lawyer lied to the creditor: a jury verdict against the debtor’s lawyer, reinstated with its damages (Chapman Lumber, 2008). The wrong was fraud, and Connecticut recognizes no independent conspiracy tort | No appellate decision located |
| Delaware | No, by statute: a creditor has no right to relief against a trustee, attorney or other adviser who has not acted in bad faith, and good faith is presumed from counseling or effecting a transfer (§ 1307(c)). No court has applied it, and the Third Circuit questioned its continued validity (Crystallex, 2018) | No, at the trial level: the Court of Chancery refuses the claim (Edgewater, 2010; Ortiz, 2025). The proper defendants are the transferor, the transferees, and the person for whose benefit the transfer was made (§ 1308(b)(1)) | No, at the trial level: the act creates no cause of action for conspiring to commit a fraudulent transfer (Edgewater, 2010), and a conspiracy cannot be predicated on a fraudulent transfer (Quadrant, Del. Ch. 2014; Fringer, 2018). No Delaware Supreme Court decision | No appellate decision located |
| Florida | No. Chapter 726 creates no cause of action against a person who assisted a transfer but never received the property (Freeman, 2004) | No. The certified question was answered in the negative, the answer confined to Chapter 726 (Freeman, 2004); the Fifth District had reached the same result under § 222.30 and Chapter 726 (BankFirst, 2003) | Open. The Supreme Court reserved the common-law question (Freeman, 2004, n.4) and no later Florida appellate decision has answered it; in 2003 two district courts sent conspiracy counts against advisers out for want of a statutory cause of action (BankFirst; Danzas Taiwan) | Control decides it, not handling: a bank that kept the debtor’s account and sent the money out by wire was a non-transferee (Freeman, 2004). Under § 550, a lawyer whose trust account receives the money is the initial transferee unless he proves both lack of control and good faith (Harwell, 11th Cir. 2010) |
| Georgia | No appellate decision located | No appellate decision located | Undecided for a non-transferee adviser. The one decision against a lawyer was brought by a woman he had represented, over her own property, and it affirmed a denial of summary judgment (Both v. Frantz, 2006) | No appellate decision located |
| Hawaii | No appellate decision located | No appellate decision located | Undecided for a non-transferee. Conspiracy to make a fraudulent transfer is a jury claim that carries punitive damages, decided against transferees on clear and convincing proof (Kekona v. Bornemann, 2015) | No appellate decision located |
| Idaho | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Illinois | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Indiana | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Iowa | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Kansas | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Kentucky | Undecided under the current act. Before 2016, federal courts reading the repealed statutes held the creditor had no claim against a non-transferee (GATX, E.D. Ky. 2012; CNH Capital, 6th Cir. 2014, unpublished); the 2016 act added the beneficiary clause those decisions relied on | Undecided under the current act. A federal court reading the repealed statutes found no aiding-and-abetting claim (Corporex, E.D. Ky. 2015) | Undecided under the current act. A federal court reading the repealed statutes called it “legally impossible” for a non-transferee to conspire in a fraudulent conveyance (GATX, E.D. Ky. 2012) | No appellate decision located |
| Louisiana | No appellate decision located. The revocatory action annuls the debtor’s act and carries no damages remedy | No appellate decision located | No appellate decision located | No appellate decision located |
| Maine | No, on a federal court’s reading (Prawer, D. Me. 1993). The statute that made a knowing helper liable in double damages, applied to a debtor’s own lawyer in 1986 (Northeast Bank v. Murphy), was repealed effective July 16, 1986 and never replaced | No, on a federal court’s reading: a fraudulent transfer is not a tort (Prawer, D. Me. 1993). The defendants were accountants | No, on the same federal reading (Prawer, D. Me. 1993) | No appellate decision located |
| Maryland | No appellate decision located. The act provides no money judgment against anyone | No appellate decision located | No appellate decision located. A bankruptcy court dismissed a conspiracy claim against an escrow company and the lawyer who advised the debtor, because a conspirator must be a party to the transfer as transferor or transferee (In re Minh Vu Hoang, Bankr. D. Md. 2012) | No appellate decision located |
| Massachusetts | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Michigan | No appellate decision located. Recovery under the act is available only against the listed transferees (MCL 566.38(2)(b)) | No appellate decision located | No appellate decision located | No appellate decision located |
| Minnesota | No appellate decision located. Recovery under the act is available only against the listed transferees (§ 513.48(b)(2)) | Split, with no precedential decision. A nonprecedential 2014 appeal reinstated the claim against a law firm at the pleading stage, and the creditor then lost at trial (Janssen); a federal court predicts the claim is not cognizable (ASI v. Aquawood, D. Minn. 2022) | Trial-level decisions only. The same nonprecedential appeal reinstated a conspiracy count against the firm (Janssen, 2014); a federal court let a conspiracy count against transferees proceed (Producers Livestock, D. Minn. 2024). No decision reaches a non-transferee | No decision located under the state act |
| Mississippi | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Missouri | No. The act’s remedies are equitable and include no damages suit against a third party who did not receive the property (Lewellen, Mo. App. 2019; the defendant was the debtor’s insurer) | No appellate decision located | No, absent a valid lien (Lewellen, Mo. App. 2019); the court refused an absolute bar | No appellate decision located |
| Montana | No appellate decision located. A federal court applying Montana law followed the majority rule that liability for a fraudulent transfer does not reach a third party who received none of the property (Magten, D. Del. 2007) | No appellate decision located. A federal court applying Montana law rejected aiding-and-abetting and conspiracy claims against the law firm that represented both parties to the transfer, because the firm received none of the property (Magten, D. Del. 2007) | No appellate decision located. A federal court applying Montana law refused conspiracy liability against a non-transferee (Magten, D. Del. 2007) | No appellate decision located |
| Nebraska | No appellate decision located. Recovery under the act is available only against the listed transferees (§ 36-809(b)(2)) | No appellate decision located | No appellate decision located | No appellate decision located |
| Nevada | No. The act gives the creditor “an equitable right to the property” and no damages claim against a non-transferee (Cadle v. Woods & Erickson, 2015, en banc; the defendant was an asset-protection law firm) | No (Cadle, 2015) | No, because the act supplies only equitable remedies; the not-a-tort rationale does not apply in Nevada (Cadle, 2015) | No appellate decision located |
| New Hampshire | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| New Jersey | No claim on the act’s own text: its money judgment runs only to the first transferee or the person for whose benefit the transfer was made (N.J.S.A. 25:2-30(b)(1)), and no decision has tested the catch-all. The Supreme Court located the lawyer’s exposure in common-law conspiracy riding on a violation of the act (Gandi, 2005) | No appellate decision located; New Jersey’s answer runs through conspiracy | Yes, at the pleading stage, against the debtor’s attorney: a creditor may sue one who assists a fraudulent transfer for conspiracy to violate the act (Gandi, 2005). The creditor must prove the agreement and knowledge elements and every element of the underlying transfer claim | No appellate decision located |
| New Mexico | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| New York | No, decided under the former act: no money-damages remedy against parties who were neither transferees nor beneficiaries (Porco, 1990). The 2020 act keeps that limit (§ 277(b)(1)(i)) and adds a catch-all (§ 276(a)(3)(iii)) that no appellate decision has construed on the point | No, unless the defendant was a transferee or benefited (Berisha, 1st Dep’t 2023, applying Porco) | No (Porco, 1990); the defendants had no dominion or control over the assets and took no benefit | A law firm’s own fee is reachable: whether a $75,000 fee paid by an insolvent debtor was a fraudulent conveyance under former DCL §§ 273 and 275 was a triable issue (Joel v. Weber, 1993) |
| North Carolina | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| North Dakota | No, by implication: a law firm could be liable only as a first transferee under the act (PHI Financial, 2016); the catch-all is untested and no common-law theory was reached | No appellate decision located | No appellate decision located | Split on the facts: money the firm passed through its trust account on the debtor’s instruction did not make it the first transferee, but the $115,000 it kept as fees did (PHI Financial, 2016), applying the bankruptcy conduit test to the state act |
| Ohio | No. Chapter 1336 applies only to the transferor and the transferee of the funds (Magnum Steel, 9th Dist. 2015; a law firm and two attorneys who only advised). The judgment section also reaches the person for whose benefit the transfer was made (§ 1336.08(B)(1)) | No common-law claim: the Supreme Court declined to recognize aiding-and-abetting liability under the circumstances of the case (DeVries Dairy, 2012). A statutory damages action survives where the assisted conduct is a crime (R.C. 2307.60; Jacobson, 2016) | Open. An appellate court with the question before it assumed the answer and disposed of the claim on the evidence (Magnum Steel, 2015) | No appellate decision located |
| Oklahoma | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Oregon | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Pennsylvania | No appellate decision located. The money judgment runs to the first transferee or the person for whose benefit the transfer was made (§ 5108(b)(1)(i)) | No appellate decision located | No appellate decision located | No decision holds a lawyer a transferee. The one law-firm case ended for the firm because the debtors received reasonably equivalent value for the fees (Trizechahn, Pa. Super. 2023) |
| Rhode Island | No appellate decision located | No appellate decision located | No appellate decision located | Yes, as first transferee: the debtor’s own attorney took a quitclaim deed for inadequate consideration and answered for a $30,000 judgment measured by the creditors’ claim (Nisenzon, 1997) |
| South Carolina | No appellate decision located. The statute voids the conveyance and has no remedies section, though courts award the creditor its debt against the taker (Future Group, 1996) | Undecided for a non-transferee adviser. The nearest decisions involve a transferee bank (Future Group, 1996) and a lawyer whose claim failed for want of actual knowledge (Gordon v. Busbee, 2012) | Undecided for a non-transferee. A creditor’s conspiracy claim was decided on the evidence against a transferee (Future Group, 1996); the elements were restated in 2021 (Paradis) | No appellate decision located |
| South Dakota | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Tennessee | No appellate decision located | No appellate decision located | Undecided for a non-transferee. The one conspiracy verdict ran against transferees and was never reviewed (Sanford, 2010); a 2015 decision rejected the claim against a non-transferee trustee for want of a wrongful act of her own (Taylor v. George) | No appellate decision located |
| Texas | No appellate decision holds the act reaches a helper. The money judgment runs to the first transferee or the person for whose benefit the transfer was made (§ 24.009(b)) | No appellate decision located | Yes, for a judgment creditor with a lien (Stonecipher, 1979). A lawyer can be exposed for knowingly drafting documents to put assets beyond a judgment creditor (Essex Crane, 2012), within the attorney-immunity test (Cantey Hanger, 2015) | No appellate decision located |
| Utah | No appellate decision located | No appellate decision located | No appellate decision located | Trial-level only. A district court held a law firm cannot exercise dominion or control over trust-account funds and is no transferee; the appellate affirmance was vacated as moot (Timothy v. Pia, 2019 UT 69) |
| Vermont | No appellate decision located | No appellate decision located | No, for a creditor without a lien, decided in 1853 against a transferee and never revisited (Hall v. Eaton, 25 Vt. 458) | No appellate decision located |
| Virginia | No. The statute only voids the conveyance and imposes no liability on the participants (La Bella Dona, 2017) | No appellate decision located; the same reasoning forecloses it | No. A fraudulent conveyance is not a wrong from which liability can pass to others, in common-law or statutory business conspiracy (La Bella Dona, 2017; the defendants included the debtors’ own law firm) | No appellate decision located |
| Washington | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| West Virginia | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
| Wisconsin | No. The money judgment runs only against transferee-side persons (§ 242.08(2)(am), (bm)), and the catch-all opens the chapter to no punitive damages (C & A Investments, 2010) | No appellate decision located | Yes, at the pleading stage. A complaint alleging a conspiracy to make fraudulent conveyances stated a claim against a co-conspirator bank without deciding whether the bank received any conveyance, with damages independent of the act (Dalton v. Meister, 1976); particularity is now required | No appellate decision located |
| Wyoming | No appellate decision located | No appellate decision located | No appellate decision located | No appellate decision located |
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