7 California opinions name it 1 courts 2023–2026 7 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Espejo v. Copley Press, Inc.green2 sentences2026We review the court’s decision for abuse of discretion (Trafton v. Youngblood (1968) 69 Cal.2d 17, 31 ; Espejo v. The Copley Press, Inc. (2017) 13 Cal.App.5th 329, 359 (Espejo)) and find none. 2026We review the court’s decision for abuse of discretion (Trafton v. Youngblood (1968) 69 Cal.2d 17, 31 ; Espejo v. The Copley Press, Inc. (2017) 13 Cal.App.5th 329, 359 (Espejo)) and find none. | 2 | 2 |
Zhang v. Superior Courtgreen2 sentences2025(See, e.g., San v. Superior Court (2013) 57 Cal.4th 364, 370 [“‘If the complaint states a cause of action under any theory, regardless of the title under which the factual basis for relief is stated, that aspect of 8 In enacting the UVTA in 2015, the Legislature amended what had previously been known as the Uniform Fraudulent Transfer Act (UFTA). 2025(See, e.g., San v. Superior Court (2013) 57 Cal.4th 364, 370 [“‘If the complaint states a cause of action under any theory, regardless of the title under which the factual basis for relief is stated, that aspect of 8 In enacting the UVTA in 2015, the Legislature amended what had previously been known as the Uniform Fraudulent Transfer Act (UFTA). | 2 | 2 |
Jhaveri v. Teitelbaumgreen2 sentences2024(Berger v. Varum (2019) 35 Cal.App.5th 1013, 1019, 1020-1021 [consequential and punitive damages available as common law remedies]; Jhaveri v. Teitelbaum (2009) 176 Cal.App.4th 740, 755 [similar]; Wisden v. Superior Court (2004) 124 Cal.App.4th 750, 756-757, 758 [parties entitled to jury trial in action to recover voidable transfer of determinate sum of money].) We question whether an action asserting the elements of a UVTA claim could be considered a common law action. 2024(Berger v. Varum (2019) 35 Cal.App.5th 1013, 1019, 1020-1021 [consequential and punitive damages available as common law remedies]; Jhaveri v. Teitelbaum (2009) 176 Cal.App.4th 740, 755 [similar]; Wisden v. Superior Court (2004) 124 Cal.App.4th 750, 756-757, 758 [parties entitled to jury trial in action to recover voidable transfer of determinate sum of money].) We question whether an action asserting the elements of a UVTA claim could be considered a common law action. | 1 | 1 |
Wisden v. Superior Courtgreen2 sentences2024(Berger v. Varum (2019) 35 Cal.App.5th 1013, 1019, 1020-1021 [consequential and punitive damages available as common law remedies]; Jhaveri v. Teitelbaum (2009) 176 Cal.App.4th 740, 755 [similar]; Wisden v. Superior Court (2004) 124 Cal.App.4th 750, 756-757, 758 [parties entitled to jury trial in action to recover voidable transfer of determinate sum of money].) We question whether an action asserting the elements of a UVTA claim could be considered a common law action. 2024(Berger v. Varum (2019) 35 Cal.App.5th 1013, 1019, 1020-1021 [consequential and punitive damages available as common law remedies]; Jhaveri v. Teitelbaum (2009) 176 Cal.App.4th 740, 755 [similar]; Wisden v. Superior Court (2004) 124 Cal.App.4th 750, 756-757, 758 [parties entitled to jury trial in action to recover voidable transfer of determinate sum of money].) We question whether an action asserting the elements of a UVTA claim could be considered a common law action. | 1 | 1 |
Moore v. Browninggreen2 sentences2024(See Moore v. Browning (Ariz. 2002) 50 P.3d 852, 857-860 [enactment of Arizona’s version of Uniform Fraudulent Transfers Act displaced any common law cause of action for fraudulent conveyance; thus, creditors’ claim was subject to uniform law’s statute of limitations].) But we need not decide the matter. 19 maximum time period to attack a [voidable] transfer, no matter whether brought under the [UVTA] or otherwise.” 14 (Macedo, at pp. 1050-1051, fn. 4.) In PGA, the Court of Appeal applied Macedo’s construction of former section 3439.09(c) to conclude that a voidable transfer claim filed more t 2024(See Moore v. Browning (Ariz. 2002) 50 P.3d 852, 857-860 [enactment of Arizona’s version of Uniform Fraudulent Transfers Act displaced any common law cause of action for fraudulent conveyance; thus, creditors’ claim was subject to uniform law’s statute of limitations].) But we need not decide the matter. 19 maximum time period to attack a [voidable] transfer, no matter whether brought under the [UVTA] or otherwise.” 14 (Macedo, at pp. 1050-1051, fn. 4.) In PGA, the Court of Appeal applied Macedo’s construction of former section 3439.09(c) to conclude that a voidable transfer claim filed more t | 1 | 1 |
Berger v. Varumgreen2 sentences2024(Berger v. Varum (2019) 35 Cal.App.5th 1013, 1019, 1020-1021 [consequential and punitive damages available as common law remedies]; Jhaveri v. Teitelbaum (2009) 176 Cal.App.4th 740, 755 [similar]; Wisden v. Superior Court (2004) 124 Cal.App.4th 750, 756-757, 758 [parties entitled to jury trial in action to recover voidable transfer of determinate sum of money].) We question whether an action asserting the elements of a UVTA claim could be considered a common law action. 2024(Berger v. Varum (2019) 35 Cal.App.5th 1013, 1019, 1020-1021 [consequential and punitive damages available as common law remedies]; Jhaveri v. Teitelbaum (2009) 176 Cal.App.4th 740, 755 [similar]; Wisden v. Superior Court (2004) 124 Cal.App.4th 750, 756-757, 758 [parties entitled to jury trial in action to recover voidable transfer of determinate sum of money].) We question whether an action asserting the elements of a UVTA claim could be considered a common law action. | 1 | 1 |
Filip v. Bucurenciugreen2 sentences2023(See Ruegg, at p. 265.) Tina also insists the remittitur did not authorize the trial court “to retry the conspiracy claim,” but she fails to acknowledge conspiracy is not an independent tort, but “ ‘a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immediate tortfeasors a common plan or design in its perpetration. [Citation.] By participation in a civil conspiracy, a coconspirator effectively adopts as his or her own the torts of other coconspirators within the ambit of the conspiracy.’ ” (Filip v. Bucurenciu (2005) 129 C 2023(See Ruegg, at p. 265.) Tina also insists the remittitur did not authorize the trial court “to retry the conspiracy claim,” but she fails to acknowledge conspiracy is not an independent tort, but “ ‘a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immediate tortfeasors a common plan or design in its perpetration. [Citation.] By participation in a civil conspiracy, a coconspirator effectively adopts as his or her own the torts of other coconspirators within the ambit of the conspiracy.’ ” (Filip v. Bucurenciu (2005) 129 C | 1 | 1 |
Rickley v. Goodfriendgreen1 sentence2023(See Rickley v. Goodfriend, supra, 212 Cal.App.4th at p. 1151 [the “‘gatekeeping function’” of § 1714.10 “‘applies only to attorney-client conspiracy claims that are not viable as a matter of law in any event’”].) A. First Cause of Action The complaint alleges defendants took a $250,000 security interest in their client’s real property as evidenced by their recording of the subject deed of trust. | 1 | 1 |
Chen v. Berenjiangreen2 sentences2023(See Nagel v. Westen, supra, 59 Cal.App.5th at p. 750 [“one’s liability under the UVTA is not contingent upon recruiting conspirators”]; Chen v. Berenjian (2019) 33 Cal.App.5th 811, 821 [“Under the UVTA, it is the transfer made or the obligation incurred by the debtor which, when made with the requisite intent or without sufficient consideration, is wrongful and, therefore, voidable”].) However, as plaintiff acknowledges, “[c]onspiracy is not a cause of action, but a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immedia 2023(See Nagel v. Westen, supra, 59 Cal.App.5th at p. 750 [“one’s liability under the UVTA is not contingent upon recruiting conspirators”]; Chen v. Berenjian (2019) 33 Cal.App.5th 811, 821 [“Under the UVTA, it is the transfer made or the obligation incurred by the debtor which, when made with the requisite intent or without sufficient consideration, is wrongful and, therefore, voidable”].) However, as plaintiff acknowledges, “[c]onspiracy is not a cause of action, but a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immedia | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Trafton v. Youngblood
green
2 sentences2026We review the court’s decision for abuse of discretion (Trafton v. Youngblood (1968) 69 Cal.2d 17, 31 ; Espejo v. The Copley Press, Inc. (2017) 13 Cal.App.5th 329, 359 (Espejo)) and find none. 2026We review the court’s decision for abuse of discretion (Trafton v. Youngblood (1968) 69 Cal.2d 17, 31 ; Espejo v. The Copley Press, Inc. (2017) 13 Cal.App.5th 329, 359 (Espejo)) and find none. | 2 | 2026–2026 |
Freitag v. McGhie
green
2 sentences2024To the extent Macedo and PGA suggested that common law actions challenging debtors’ transfers were entirely separate and independent from the UVTA, we believe their analysis was based in part on their misreading of Cortez and disagree for the reasons stated above. 18 The other case RSMH discusses, Freitag v. McGhie (Wash. 1997) 947 P.2d 1186 , is irrelevant. 2024To the extent Macedo and PGA suggested that common law actions challenging debtors’ transfers were entirely separate and independent from the UVTA, we believe their analysis was based in part on their misreading of Cortez and disagree for the reasons stated above. 18 The other case RSMH discusses, Freitag v. McGhie (Wash. 1997) 947 P.2d 1186 , is irrelevant. | 1 | 2024–2024 |
Applied Equipment Corp. v. Litton Saudi Arabia Ltd.
green
2 sentences2023(See Nagel v. Westen, supra, 59 Cal.App.5th at p. 750 [“one’s liability under the UVTA is not contingent upon recruiting conspirators”]; Chen v. Berenjian (2019) 33 Cal.App.5th 811, 821 [“Under the UVTA, it is the transfer made or the obligation incurred by the debtor which, when made with the requisite intent or without sufficient consideration, is wrongful and, therefore, voidable”].) However, as plaintiff acknowledges, “[c]onspiracy is not a cause of action, but a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immedia 2023(See Nagel v. Westen, supra, 59 Cal.App.5th at p. 750 [“one’s liability under the UVTA is not contingent upon recruiting conspirators”]; Chen v. Berenjian (2019) 33 Cal.App.5th 811, 821 [“Under the UVTA, it is the transfer made or the obligation incurred by the debtor which, when made with the requisite intent or without sufficient consideration, is wrongful and, therefore, voidable”].) However, as plaintiff acknowledges, “[c]onspiracy is not a cause of action, but a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immedia | 1 | 2023–2023 |
Cortese v. Sherwood
green
2 sentences2023(See Nagel v. Westen, supra, 59 Cal.App.5th at p. 750 [“one’s liability under the UVTA is not contingent upon recruiting conspirators”]; Chen v. Berenjian (2019) 33 Cal.App.5th 811, 821 [“Under the UVTA, it is the transfer made or the obligation incurred by the debtor which, when made with the requisite intent or without sufficient consideration, is wrongful and, therefore, voidable”].) However, as plaintiff acknowledges, “[c]onspiracy is not a cause of action, but a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immedia 2023(See Nagel v. Westen, supra, 59 Cal.App.5th at p. 750 [“one’s liability under the UVTA is not contingent upon recruiting conspirators”]; Chen v. Berenjian (2019) 33 Cal.App.5th 811, 821 [“Under the UVTA, it is the transfer made or the obligation incurred by the debtor which, when made with the requisite intent or without sufficient consideration, is wrongful and, therefore, voidable”].) However, as plaintiff acknowledges, “[c]onspiracy is not a cause of action, but a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immedia | 1 | 2023–2023 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.