Ohio Revised Code

Ohio Rev. Code § 1336.05 (2026)

Claims arising before the transfer or obligation incurred

✓ current as of May 2026
Find cases: SyfertCases citing this section ORCcodes.ohio.gov (official) Justiaon Justia CornellLII Search CasesGoogle Scholar

(A) A transfer made or an obligation incurred by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation without receiving a reasonably equivalent value in exchange for the transfer or obligation and the debtor was insolvent at that time or the debtor became insolvent as a result of the transfer or obligation.

(B) A transfer made or an obligation incurred by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the transfer was made to or the obligation was incurred with respect to an insider for an antecedent debt, the debtor was insolvent at that time, and the insider had reasonable cause to believe that the debtor was insolvent.

Notes of Decisions
Cited in 78 cases (19 in the last 5 years), 1985–2026 · leading case: Rieser v. Hayslip (In Re Canyon Sys. Corp.), 343 B.R. 615 (Bankr. S.D. Ohio 2006).
Sort: Relevance Newest Treatment
Rieser v. Hayslip (In Re Canyon Sys. Corp.), 343 B.R. 615 (Bankr. S.D. Ohio 2006). · cites it 10× “, Ohio Rev. Code Ann. § 1336.05 , which provides that a transfer is avoidable if the debtor made the transfer “without receiving reasonably equivalent value in exchange for the transfer”].”
Weaner & Assocs., L.L.C. v. 369 W. First, L.L.C., 2020 Ohio 48 (Ohio Ct. App. 2020). · cites it 19× “Plaintiffs have said that they agree with Defendants that the trial court erroneously granted relief under R.C. 1336.05 with respect to the November 2015 transfers to NW and Olympia.”
Tricarichi v. Comm'r, 2015 T.C. Memo. 201 (Tax Ct. 2015). · cites it 14× “OUFTA section 1336.04(A)(1) , the actual fraud provision, applies in the case of any creditor regardless of whether his "claim * * * arose before or after the transfer was made.”
In Re Taubman, 160 B.R. 964 (Bankr. S.D. Ohio 1993). · cites it 5× “04 with § 548(a)(2)(B)©; O.R.C. § 1336.05 with 11 U.S.C. § 548 (a)(2)(B)(ii); O.”
Daneman v. Stanley (In Re Stanley), 384 B.R. 788 (Bankr. S.D. Ohio 2008). · cites it 6× “…the debtor was insolvent at that time, and the insider had reasonable cause to believe that the debtor was insolvent. Ohio Rev.Code Ann. § 1336.05.”
Youngstown Osteopathic Hosp. Ass'n v. Pathways Ctr. for Geriatric Psychiatry, Inc. (In Re Youngstown Osteopathic Hosp. Ass'n), 280 B.R. 400 (Bankr. N.D. Ohio 2002). · cites it 7× “For a creditor whose claim against a debtor arose before the transfer took place, Ohio Revised Code § 1336.05 provides the statutory framework under which the creditor must prove its case.”
Premier Therapy, L.L.C v. Childs, 2016 Ohio 7934 (Ohio Ct. App. 2016). · cites it 3× “Constructive fraud is also addressed in R.C. 1336.05. For instance, R.C. 1336.05(A) provides a transfer is fraudulent as to a creditor, whose claim arose before the transfer, if the debtor made the transfer without receiving a reasonably equivalent value in exchange for the…”
Liquidating Tr. of the Amcast Unsecured Creditor Liquidating Trust v. Baker (In Re Amcast Indus. Corp.), 365 B.R. 91 (Bankr. S.D. Ohio 2007). · cites it 3× “Ohio Rev.Code § 1336.05. Ladehoff argues that the fraudulent transfer claim must be dismissed regardless of which statutory section it is based upon because Amcast was legally bound to make the transfers to Ladehoff pursuant to the terms of the Executive Agreement.”
SPC Plastics Corp. v. Griffith (In Re Structurlite Plastics Corp.), 193 B.R. 451 (Bankr. S.D. Ohio 1995). · cites it 7× “Plaintiffs’ Claims Under Section 5 of the UFCA (Former Ohio Rev.Code § 1336.05) (Unreasonably Small Capital) Former Ohio Rev.”
Silagy v. Gagnon (In Re Gabor), 280 B.R. 149 (Bankr. N.D. Ohio 2002). · cites it 3× “At least two of these creditors had claims prior to the date of the transfer.”
James v. McCoy, 56 F. Supp. 2d 919 (S.D. Ohio 1998). · cites it 9× “For a violation of § 1336.05(A) or § 1336.04(A)(2), the action must be brought within four years after the transfer was made or the obligation was incurred.”
Commonwealth Land Title Ins. Co. v. Choice Title Agency, Inc., 2012 Ohio 2824 (Ohio Ct. App. 2012). · cites it 8× “MARUNA] ON ITS CLAIM FOR FRAUDULENT TRANSFER UNDER R.C. §1336.05. [MS. MARUNA] TRANSFERRED HER INTEREST IN THE MARUNA PROPERTIES WITHOUT RECEIVING A REASONABLY EQUIVALENT VALUE IN EXCHANGE FOR THE TRANSFER AND SHE BECAME INSOLVENT AS A RESULT OF THE TRANSFER.”
Show all 78 citing cases →
— Ohio Rev. Code § 1336.05(A) — 41 cases
Weaner & Assocs., L.L.C. v. 369 W. First, L.L.C., 2020 Ohio 48 (Ohio Ct. App. 2020). “Plaintiffs have said that they agree with Defendants that the trial court erroneously granted relief under R.C. 1336.05 with respect to the November 2015 transfers to NW and Olympia.”
Rieser v. Hayslip (In Re Canyon Sys. Corp.), 343 B.R. 615 (Bankr. S.D. Ohio 2006). “, Ohio Rev. Code Ann. § 1336.05 , which provides that a transfer is avoidable if the debtor made the transfer “without receiving reasonably equivalent value in exchange for the transfer”].”
DeNune v. Consol. Capital of North Am., Inc., 288 F. Supp. 2d 844 (N.D. Ohio 2003).
Whittaker v. Groves Venture, LLC (In re Bolon), 538 B.R. 391 (Bankr. S.D. Ohio 2015).
Youngstown Osteopathic Hosp. Ass'n v. Pathways Ctr. for Geriatric Psychiatry, Inc. (In Re Youngstown Osteopathic Hosp. Ass'n), 280 B.R. 400 (Bankr. N.D. Ohio 2002). “For a creditor whose claim against a debtor arose before the transfer took place, Ohio Revised Code § 1336.05 provides the statutory framework under which the creditor must prove its case.”
— Ohio Rev. Code § 1336.05(A)(1) — 1 case
Dymarkowski v. McConegly (Bankr. N.D. Ohio 2021).
— Ohio Rev. Code § 1336.05(B) — 17 cases
Prudential Ins. Co. of Am. v. Sci. Park Ltd. P'ship, 667 N.E.2d 437 (Ohio Ct. App. 1995).
Premier Therapy, L.L.C v. Childs, 2016 Ohio 7934 (Ohio Ct. App. 2016). “Constructive fraud is also addressed in R.C. 1336.05. For instance, R.C. 1336.05(A) provides a transfer is fraudulent as to a creditor, whose claim arose before the transfer, if the debtor made the transfer without receiving a reasonably equivalent value in exchange for the…”
James v. McCoy, 56 F. Supp. 2d 919 (S.D. Ohio 1998). “For a violation of § 1336.05(A) or § 1336.04(A)(2), the action must be brought within four years after the transfer was made or the obligation was incurred.”
Youngstown Osteopathic Hosp. Ass'n v. Pathways Ctr. for Geriatric Psychiatry, Inc. (In Re Youngstown Osteopathic Hosp. Ass'n), 280 B.R. 400 (Bankr. N.D. Ohio 2002). “For a creditor whose claim against a debtor arose before the transfer took place, Ohio Revised Code § 1336.05 provides the statutory framework under which the creditor must prove its case.”
In Re Cincinnati Gear Co., 304 B.R. 784 (Bankr. S.D. Ohio 2003).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.