California Codes

Cal. Civil Code § 3439 (2026)

✓ current as of May 2026

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This chapter may be cited as the Uniform Voidable Transactions Act.

Notes of Decisions

Cited in 205 cases (60 in the last 5 years), 1939–2026 · leading case: Crystallex Int'l Corp. v. Petróleos De Venezuela, S.A., 879 F.3d 79 (3rd Cir. 2018).

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Crystallex Int'l Corp. v. Petróleos De Venezuela, S.A., 879 F.3d 79 (3rd Cir. 2018). · cites it 2× “The defendant bank in Gutierrez did not argue that it was not liable under the California fraudulent transfer statute, Cal. Civil Code § 3439 , based on its non-debtor status.”

Neilson v. Union Bank of California, N.A., 290 F. Supp. 2d 1101 (C.D. Cal. 2003). · cites it 2× “Whether The Complaint Adequately Pleads Fraudulent Transfer The ninth cause of action is brought by Neilson pursuant to California’s Uniform Fraudulent Transfer Act (“CUFTA”), California Civil Code § 3439. The claim seeks to avoid and recover intentional fraudulent transfers…”

E. & J. Gallo Winery v. Encana Corp., 503 F.3d 1027 (9th Cir. 2007). · cites it 2× “, California's Uniform Fraudulent Transfer Act, CAL. CIV. CODE §§ 3439 et seq., and under a theory of unjust enrichment.”

Voris v. Lampert, 446 P.3d 284 (Cal. 2019). “And the Uniform Voidable Transactions Act (Civ. Code, § 3439 et seq. ) permits a defrauded creditor to reach property that has been fraudulently transferred by a judgment debtor to a third party.”

Fremont Indem. Co. v. Fremont Gen. Corp., 2007 Cal. Daily Op. Serv. 2253 (Cal. Ct. App. 2007). “or the economic benefit received from its prior use of Comstock’s net operating losses; (3) breach of contract, alleging the failure to pay amounts due under the intercompany tax allocation agreement; (4) breach of fiduciary duty; (5) unjust enrichment; (6) constructive trust;…”

Zahn v. Yucaipa Capital Fund, 218 B.R. 656 (D.R.I. 1998). · cites it 3× “However, defendants argue that California’s version of the UFTA, Cal. Civ.Code § 3439, should govern. Both parties address the relevant contacts of Rhode Island and California with this ease, contending that the law of one state or the other should govern.”

Opperman v. Path, Inc., 87 F. Supp. 3d 1018 (N.D. Cal. 2014). · cites it 2× “; violation of the Uniform Fraudulent Trans *1030 fer Act, Cal. Civ.Code § 3439; violation of the Texas Wiretap Acts, Tex.”

Rooz v. Kimmel (In Re Kimmel), 378 B.R. 630 (9th Cir. BAP 2007). · cites it 2× “Cal. Civ.Code § 3439, et seq. In response, Roberta Kimmel reopened her 1993 bankruptcy case, removed the 2006 Litigation to the bankruptcy court, and moved for judgment on the pleadings pursuant to Fed.”

Chen v. Berenjian, 245 Cal. Rptr. 3d 378 (Cal. Ct. App. 5th 2019). “*814 INTRODUCTION After obtaining money judgments against Shazad Berenjian, Pang Yen Chen sued him and his brother Sharmad Berenjian 1 for fraudulent transfer under the Uniform Voidable Transactions Act (UVTA), Civil Code section 3439 et seq., formerly known as the Uniform…”

Berger v. Varum, 248 Cal. Rptr. 3d 51 (Cal. Ct. App. 5th 2019). “) Civil Code section 3439 et seq. is the Uniform Voidable Transactions Act (UVTA).”

Gen. Elec. Capital Auto Lease, Inc. v. Broach (In Re Lucas Dallas, Inc.), 185 B.R. 801 (9th Cir. BAP 1995). · cites it 2× “These transfers were alleged to be avoidable under section 548, and section 544 and Cal.Civ.Code § 3439 et seq. (“California Uniform Fraudulent Transfer Act”).”

Tatung Co. v. Shu Tze Hsu, 217 F. Supp. 3d 1138 (C.D. Cal. 2016). “See Cal. Civ. Code § 3439 . . “[T]here is no fiduciary duty prescribed under California law that is owed to creditors by directors of a corporation solely by virtue of its operating in the ‘zone’ or ‘vicinity’ of insolvency.”

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