Indiana Code

Ind. Code § 32-18-2-19 (2026)

Statutes of limitation; extinguishment of claim for relief

✓ current as of May 2026

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Sec. 19. A claim for relief with respect to a transfer or obligation under this chapter is extinguished unless brought as follows:

(1) If brought under section 14(a)(1) of this chapter, an action is extinguished unless brought not later than the later of the following:

(A) Four (4) years after the transfer was made or the obligation was incurred.

(B) One (1) year after the transfer or obligation was or could reasonably have been discovered by the claimant.

(2) If brought under section 14(a)(2) or 15 of this chapter, an action is extinguished unless it is brought not later than four (4) years after the transfer was made or the obligation was incurred.

[Pre-2002 Recodification Citation: 32-2-7-19.]

As added by P.L.2-2002, SEC.3. Amended by P.L.61-2017, SEC.17.

Notes of Decisions

Cited in 7 cases, 2008–2018 · leading case: Freeland v. Enodis Corp., 540 F.3d 721 (7th Cir. 2008).

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Freeland v. Enodis Corp., 540 F.3d 721 (7th Cir. 2008). “Ind.Code § 32-18-2-19(1)(B); 28 U.S.C. § 3306 (b)(1).”

Boyer v. Crown Stock Distrib., Inc., 587 F.3d 787 (7th Cir. 2009). “The action was timely, despite the length of time since the alleged fraudulent conveyance, because the bankruptcy petition was filed within the four-year “look back” period of the Uniform Fraudulent Transfer Act, Ind.Code § 32-18-2-19(2), and the trustee initiated this suit…”

Hair v. Schellenberger, 966 N.E.2d 693 (Ind. Ct. App. 2012). · cites it 2× “Ind.Code § 32-18-2-19. Lawyers Title argues that Hair failed to raise this issue within the required timeframe.”

Finn v. All. Bank, 838 N.W.2d 585 (Minn. Ct. App. 2013). “160/10 (West 2010); Ind.Code Ann. § 32-18-2-19 (LexisNexis 2002); Iowa Code §§ 684.”

Karleen Spann Perry v. Larry Spann, & Madison Riverport, LLC c/o Anthony Hammock (mem. dec.) (Ind. Ct. App. 2018). · cites it 2× “I.C. § 32-18-2-19. Court of Appeals of Indiana | Memorandum Decision 39A01-1708-DR-1783 | February 8, 2018 Page 4 of 16 suggested that the transfer may have lacked consideration and been fraudulent.”

Calvin Hair v. Mike Schellenberger & Lawyers Title Ins. Corp., Wells Fargo Bank, N.A., Felix Adejare, & Sharon Adejare (Ind. Ct. App. 2012). · cites it 2× “Ind. Code § 32-18-2-19 . Lawyers Title 4 We note Schellenberger’s argument that we lack subject matter jurisdiction to decide this issue because the trial court’s denial of a motion for summary judgment is not a final appealable order.”

R. David Boyer v. Crown Stock Distrib. (7th Cir. 2009). “The action was timely, despite the length of time since the alleged fraudulent conveyance, because the bankruptcy petition was filed within the four-year “look back” period of the Uniform Fraudulent Transfer Act, Ind. Code § 32-18-2-19 (2), and the trustee initiated this suit…”

— Ind. Code § 32-18-2-19(1)(B) — 1 case

Freeland v. Enodis Corp., 540 F.3d 721 (7th Cir. 2008). “Ind.Code § 32-18-2-19(1)(B); 28 U.S.C. § 3306 (b)(1).”

— Ind. Code § 32-18-2-19(2) — 1 case

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