Legal Opinion

Douglas v. Hill

Court of Appeals of Washington

Decided January 20, 2009No. 60428-7-IPublishedCited by 4 opinions

1Opinion of the CourtGrosse, J.

¶1 A creditor need only establish a right to collect payment in order to void a fraudulent transfer under the Uniform Fraudulent Transfer Act (UFTA).1 Hence, a creditor’s failure to record a lien with the local auditor does not preclude a claim under the UFTA. Here, to avoid paying a judgment against her, the defendant transferred her interest in real property to her husband, from whom she is *763legally separated. Because the transfer was made for the purpose of avoiding a creditor, such transfer is fraudulent under the UFTA as a matter of law. We reverse the trial court.

FACTS

¶2 Diane Hill…

2Cases cited8 opinions

  1. Clearwater v. Skyline Construction Co.Court of Appeals of Washington · 1992
  2. Sedwick v. GwinnCourt of Appeals of Washington · 1994
  3. Davis v. NielsonCourt of Appeals of Washington · 1973
  4. Richau v. RaynerCourt of Appeals of Washington · 1999
  5. South Kitsap Family Worship Center v. WeirCourt of Appeals of Washington · 2006

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3Cited by4 opinions

  1. Official Comm. Unsecured Creditors of HH Liquidation, LLC v. Comvest Grp. Holdings, LLC (In re HH Liquidation, LLC)United States Bankruptcy Court, D. Delaware · 2018
  2. Kreidler v. Cascade National InsuranceCourt of Appeals of Washington · 2014
  3. BGH Holdings, LLC v. DL Evans BankDistrict Court, W.D. Washington · 2023
  4. James Feltman v. Mike Kreidler And Cascade National Insurance CompanyCourt of Appeals of Washington · 2014

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