Ohio Revised Code

Ohio Rev. Code § 1336.07 (2026)

Remedies of creditor

✓ current as of May 2026
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(A) In an action for relief arising out of a transfer or an obligation that is fraudulent under section 1336.04 or 1336.05 of the Revised Code, a creditor or a child support enforcement agency on behalf of a support creditor, subject to the limitations in section 1336.08 of the Revised Code, may obtain one of the following:

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

(2) An attachment or garnishment against the asset transferred or other property of the transferee in accordance with Chapters 2715. and 2716. of the Revised Code;

(3) Subject to the applicable principles of equity and in accordance with the Rules of Civil Procedure, any of the following:

(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;

(c) Any other relief that the circumstances may require.

(B) If a creditor or child support enforcement agency has obtained a judgment on a claim against the debtor, the creditor or agency, if the court so orders, may levy execution on the asset transferred or its proceeds in accordance with Chapter 2329. of the Revised Code.

Notes of Decisions
Cited in 79 cases (11 in the last 5 years), 1968–2026 · leading case: In Re Taubman, 160 B.R. 964 (Bankr. S.D. Ohio 1993).
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In Re Taubman, 160 B.R. 964 (Bankr. S.D. Ohio 1993). · cites it 12× “(2) O.R.C. § 1336.07 . e. Constructive Fraud .”
UBS Fin. servs., Inc. v. Lacava, 2018 Ohio 3165 (Ohio Ct. App. 2018). · cites it 13× “19, and R.C. 1336.07. 6. After correctly ruling AIM is granted R.”
Premier Therapy, L.L.C v. Childs, 2016 Ohio 7934 (Ohio Ct. App. 2016). · cites it 6× “” Appellants allege the buyer of the Holander House realty and business assets was a necessary party under R.C. 1336.07. This statute provides: (A) In an action for relief arising out of a transfer or an obligation that is fraudulent under section 1336.”
Slone v. Lassiter (In Re Grove-Merritt), 406 B.R. 778 (Bankr. S.D. Ohio 2009). · cites it 7× “Therefore, pursuant to § 550(a) and ORC § 1336.07, the Trustee is entitled to recover from the Defendant the amount of $11,070.”
Stein v. Brown, 480 N.E.2d 1121 (Ohio 1985). · cites it 4× “07 which states: “Every conveyance made and every obligation incurred with actual intent, as distinguished from intent presumed in law, to hinder, delay, or *308 defraud either present or future creditors, is fraudulent as to both present or future creditors.”
McKinley Fed. Sav. & Loan v. Pizzuro Enter., Inc., 585 N.E.2d 496 (Ohio Ct. App. 1990). · cites it 6× “The trial court based its judgment in this case on Section 7 of the Uniform Fraudulent Conveyance Act, R.C. 1336.07, which provides: “Every conveyance made and every obligation incurred with actual intent, as distinguished from intent presumed in law, to hinder, delay, or…”
Aristocrat Lakewood Nursing Home v. Mayne, 729 N.E.2d 768 (Ohio Ct. App. 1999). · cites it 4× “R.C. 1336.07 generally describes remedies in fraudulent conveyance actions and provides: “(A) In an action for relief arising out of a transfer or an obligation that is fraudulent under section 1336.”
Toledo Trust Co. v. Poole (In Re Poole), 15 B.R. 422 (Bankr. N.D. Ohio 1981). · cites it 5× “04 and § 1336.07 of the Ohio Revised Code. In order to determine whether Plaintiff has shown a strong or substantial probability of success on the merits, the proofs adduced thus far must be evaluated under the respective terms of each statutory provision.”
UBS Fin. Servs., Inc. v. Lacava, 2018 Ohio 3276 (Ohio Ct. App. 2018). · cites it 7× “The trial court made plain error by violating the doctrine of separation of powers, not following the statutory language in R.C. 1336.07, first in applying the limitations of R.”
Blood v. Nofzinger, 834 N.E.2d 358 (Ohio Ct. App. 2005). · cites it 2× “R.C. 1336.07(A)(1). 5 . {¶ a} When denying Blood’s initial, earlier motion for summary judgment in this case, the trial court wrote: *562 {If b} "If the matters alleged by Plaintiff, which the Court has summarized, are true, then the failure of the Nofzingers to disclose to the…”
Profeta v. Lombardo, 600 N.E.2d 360 (Ohio Ct. App. 1991). · cites it 4× “Chapter 1336, entitled “Fraudulent Conveyances,” which was made effective on October 23, 1961, was repealed and replaced by a newly enacted R.C. Chapter 1336, entitled “Ohio Uniform Fraudulent Transfer Act,” which became effective on September 28, 1990 during the pendency of the…”
Brown Bark II, L.P. v. Coakley, 934 N.E.2d 991 (Ohio Ct. App. 2010). · cites it 5× “R.C. 1336.07(A). {¶ 18} R.C. 1336.08(B)(1), in turn, provides that to the extent a transfer is voidable under section 1336.”
Show all 79 citing cases →
— Ohio Rev. Code § 1336.07(1) — 1 case
In Re Taubman, 160 B.R. 964 (Bankr. S.D. Ohio 1993). “(2) O.R.C. § 1336.07 . e. Constructive Fraud .”
— Ohio Rev. Code § 1336.07(3)(a) — 1 case
Hamm v. Thunderbird Global Dev., LLC (S.D. Ohio 2022).
— Ohio Rev. Code § 1336.07(3)(c) — 1 case
Hamm v. Thunderbird Global Dev., LLC (S.D. Ohio 2022).
— Ohio Rev. Code § 1336.07(A) — 6 cases
Brown Bark II, L.P. v. Coakley, 934 N.E.2d 991 (Ohio Ct. App. 2010). “R.C. 1336.07(A). {¶ 18} R.C. 1336.08(B)(1), in turn, provides that to the extent a transfer is voidable under section 1336.”
UBS Fin. Servs., Inc. v. Lacava, 2018 Ohio 3276 (Ohio Ct. App. 2018). “The trial court made plain error by violating the doctrine of separation of powers, not following the statutory language in R.C. 1336.07, first in applying the limitations of R.”
In re Est. of McDaniel, 2023 Ohio 1065 (Ohio Ct. App. 2023).
Wuliger v. Cannella Response Television, Inc., 865 F. Supp. 2d 836 (N.D. Ohio 2011).
Walters v. Walters, 2013 Ohio 2554 (Ohio Ct. App. 2013).
— Ohio Rev. Code § 1336.07(A)(1) — 16 cases
Francisco A. Mateo M.D., Inc. v. Proia, 2023 Ohio 3908 (Ohio Ct. App. 2023).
Brown Bark II, L.P. v. Coakley, 934 N.E.2d 991 (Ohio Ct. App. 2010). “R.C. 1336.07(A). {¶ 18} R.C. 1336.08(B)(1), in turn, provides that to the extent a transfer is voidable under section 1336.”
Blood v. Nofzinger, 834 N.E.2d 358 (Ohio Ct. App. 2005). “R.C. 1336.07(A)(1). 5 . {¶ a} When denying Blood’s initial, earlier motion for summary judgment in this case, the trial court wrote: *562 {If b} "If the matters alleged by Plaintiff, which the Court has summarized, are true, then the failure of the Nofzingers to disclose to the…”
Mancz v. McHenry, 2021 Ohio 82 (Ohio Ct. App. 2021).
Aristocrat Lakewood Nursing Home v. Mayne, 729 N.E.2d 768 (Ohio Ct. App. 1999). “R.C. 1336.07 generally describes remedies in fraudulent conveyance actions and provides: “(A) In an action for relief arising out of a transfer or an obligation that is fraudulent under section 1336.”
— Ohio Rev. Code § 1336.07(A)(2) — 1 case
UBS Fin. servs., Inc. v. Lacava, 2018 Ohio 3165 (Ohio Ct. App. 2018). “19, and R.C. 1336.07. 6. After correctly ruling AIM is granted R.”
— Ohio Rev. Code § 1336.07(A)(3) — 1 case
UBS Fin. servs., Inc. v. Lacava, 2018 Ohio 3165 (Ohio Ct. App. 2018). “19, and R.C. 1336.07. 6. After correctly ruling AIM is granted R.”
— Ohio Rev. Code § 1336.07(A)(3)(a) — 1 case
UBS Fin. servs., Inc. v. Lacava, 2018 Ohio 3165 (Ohio Ct. App. 2018). “19, and R.C. 1336.07. 6. After correctly ruling AIM is granted R.”
— Ohio Rev. Code § 1336.07(A)(3)(b) — 1 case
W. Bay Care & Rehab. Ctr. v. Est. of Nay, 2019 Ohio 4306 (Ohio Ct. App. 2019).
— Ohio Rev. Code § 1336.07(A)(3)(c) — 8 cases
Premier Therapy, L.L.C v. Childs, 2016 Ohio 7934 (Ohio Ct. App. 2016). “” Appellants allege the buyer of the Holander House realty and business assets was a necessary party under R.C. 1336.07. This statute provides: (A) In an action for relief arising out of a transfer or an obligation that is fraudulent under section 1336.”
Blood v. Nofzinger, 834 N.E.2d 358 (Ohio Ct. App. 2005). “R.C. 1336.07(A)(1). 5 . {¶ a} When denying Blood’s initial, earlier motion for summary judgment in this case, the trial court wrote: *562 {If b} "If the matters alleged by Plaintiff, which the Court has summarized, are true, then the failure of the Nofzingers to disclose to the…”
Aristocrat Lakewood Nursing Home v. Mayne, 729 N.E.2d 768 (Ohio Ct. App. 1999). “R.C. 1336.07 generally describes remedies in fraudulent conveyance actions and provides: “(A) In an action for relief arising out of a transfer or an obligation that is fraudulent under section 1336.”
St. Clairsville Pointe, Inc. v. Musilli, 2022 Ohio 2646 (Ohio Ct. App. 2022).
Individual Bus. Servs. v. Carmack, 2013 Ohio 4819 (Ohio Ct. App. 2013).
— Ohio Rev. Code § 1336.07(B) — 1 case
Premier Therapy, L.L.C v. Childs, 2016 Ohio 7934 (Ohio Ct. App. 2016). “” Appellants allege the buyer of the Holander House realty and business assets was a necessary party under R.C. 1336.07. This statute provides: (A) In an action for relief arising out of a transfer or an obligation that is fraudulent under section 1336.”
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