Thursday, September 6, 2012

ACLI Government Securities, Inc. v. Rhoades case brief

653 F. Supp. 1388 (S.D.N.Y. 1987)

FACTS
P, ACLI, sues D, Daniel Rhoades for judgment of over $1,500,000.
D conveys property to sister.
D --> house ($325,000) --> D's sister (paid $1).
D and sister were tenants in common of the property (D 3/5, D's sister 2/5).

ISSUE
-Was the conveyance of a house valued at $325,000, sold for $1, a fraudulent conveyance?

HOLDING
-Yes.  The conveyance was made with actual intent to defraud P.

ANALYSIS
-Here we are dealing with family members.  In an intrafamily transaction there is a heavier burden on the transferee to establish fair consideration for the transfer.
-Here the transfer was made a day before the judgment.
-Conveyance was made in secret.
-Actual intent is not required to set aside the fraudulent transfer.
-D's sister retains her 2/5 ownership as tenant-in-common.


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