Haw. Rev. Stat. » Haw. Rev. Stat. / Chapter 651C
Hawaii Revised Statutes

Haw. Rev. Stat. § 651C-7 (2026)

] Remedies of creditors

✓ current as of July 2026
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     [§651C-7]  Remedies of creditors.  (a)  In any action for relief against a transfer or obligation under this chapter, a creditor, subject to the limitations provided in section 651C-8, may obtain:

     (1)  Avoidance of the transfer or obligation to the extent necessary to satisfy the creditor's claim;

     (2)  An attachment or other provisional remedy against the asset transferred or other property of the transferee in accordance with the procedure prescribed by chapter 651;

     (3)  Subject to applicable principles of equity and in accordance with applicable civil rules of procedure:

          (A)  An injunction against further disposition by the debtor or a transferee, or both, of the asset transferred or of other property;

          (B)  Appointment of a receiver to take charge of the asset transferred or of other property of the transferee; or

          (C)  Any other relief the circumstances may require.

     (b)  If a creditor has obtained a judgment on a claim against the debtor, the creditor may, if the court so orders, levy execution on the asset transferred or its proceeds. [L 1985, c 216, pt of §1]

 

Case Notes

 

  Action in which plaintiff made fraudulent transfer claims under the Hawaii uniform fraudulent transfer act, seeking to avoid the transfer of real property to the extent necessary to satisfy plaintiff's claims and/or to grant plaintiff other relief under subsection (a), was an appropriate subject of a lis pendens under the Hawaii doctrine of lis pendens, codified in §634-51.  457 F. Supp. 2d 1121 (2006).

  Petitioners were entitled to a variety of means (§§651C-8 and 651C-10 and this section) to secure a full recovery of their losses from respondent and/or the asset fraudulently transferred to respondent, but only once, not twice; moreover, nothing in this chapter requires petitioners to elect one remedy over another.  This chapter does not, however, allow petitioners recovery of both the asset transferred (regardless of its value) and, in addition, a judgment in the full amount of their damages.  130 H. 58 (App.), 305 P.3d 474 (2013).

 

 

Notes of Decisions
Cited in 5 cases (4 in the last 5 years), 2018–2025 · leading case: Adam Lee v. Dane Field, 889 F.3d 639 (9th Cir. 2018).
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Adam Lee v. Dane Field, 889 F.3d 639 (9th Cir. 2018). “” Haw. Rev. Stat. § 651C-7(a)(1). IN RE LEE 9 trustee argued that an order requiring Lee to turn over the Palua properties was necessary because Lee had been interfering with efforts to liquidate the properties for the estate.”
Evan Auld-Susott v. Lauryn Galindo (9th Cir. 2021). “See Haw. Rev. Stat. § 651C-7 (providing remedies only for creditors).”
Auld-Susott v. Galindo (D. Haw. 2021). “” (citing Haw. Rev. Stat. § 651C-7)). The debts that Plaintiffs now assert render them creditors of D.”
Pac. Links US Holdings, Inc. v. Tianjin Dinghui Hongjun Equity Inv. Partners (Bankr. D. Haw. 2022). “If a transfer is fraudulent under this section, Haw. Rev. Stat. § 651C-7 allows a qualifying creditor to avoid the transfer.”
Field v. Honda Aircraft Co., LLC (Bankr. D. Haw. 2025). “, Haw. Rev. Stat. § 651C-7(a)(3) (providing that, in a state law fraudulent transfer case, the court “may” impose certain remedies “subject to applicable principles of equity .”
— Haw. Rev. Stat. § 651C-7(a)(1) — 1 case
Adam Lee v. Dane Field, 889 F.3d 639 (9th Cir. 2018). “” Haw. Rev. Stat. § 651C-7(a)(1). IN RE LEE 9 trustee argued that an order requiring Lee to turn over the Palua properties was necessary because Lee had been interfering with efforts to liquidate the properties for the estate.”
— Haw. Rev. Stat. § 651C-7(a)(3) — 1 case
Field v. Honda Aircraft Co., LLC (Bankr. D. Haw. 2025). “, Haw. Rev. Stat. § 651C-7(a)(3) (providing that, in a state law fraudulent transfer case, the court “may” impose certain remedies “subject to applicable principles of equity .”
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