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Ohio Revised Code

Ohio Rev. Code § 1336.09 (2026)

Statute of limitations

✓ current as of May 2026
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Effective:
September 28, 1990
Latest Legislation:
House Bill 506 - 118th General Assembly
PDF:
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A claim for relief with respect to a transfer or an obligation that is fraudulent under section 1336.04 or 1336.05 of the Revised Code is extinguished unless an action is brought in accordance with one of the following:

(A) If the transfer or obligation is fraudulent under division (A)(1) of section 1336.04 of the Revised Code, within four years after the transfer was made or the obligation was incurred or, if later, within one year after the transfer or obligation was or reasonably could have been discovered by the claimant;

(B) If the transfer or obligation is fraudulent under division (A)(2) of section 1336.04 or division (A) of section 1336.05 of the Revised Code, within four years after the transfer was made or the obligation was incurred;

(C) If the transfer or obligation is fraudulent under division (B) of section 1336.05 of the Revised Code, within one year after the transfer was made or the obligation was incurred.
Notes of Decisions
Cited in 57 cases (16 in the last 5 years), 1968–2026 · leading case: UBS Fin. servs., Inc. v. Lacava, 2018 Ohio 3165 (Ohio Ct. App. 2018).
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UBS Fin. servs., Inc. v. Lacava, 2018 Ohio 3165 (Ohio Ct. App. 2018). · cites it 19× “AIM argued that any and all claims that UBS asserted against AIM were barred by the statute of limitations set forth in R.C. 1336.09, governing claims for fraudulent transfer.”
James v. McCoy, 56 F. Supp. 2d 919 (S.D. Ohio 1998). · cites it 19× “See Ohio Rev. Code Ann. § 1336.09 (B). For a violation of § 1336.”
Bradley v. Miller, 96 F. Supp. 3d 753 (S.D. Ohio 2015). · cites it 8× “” Ohio Rev.Code § 1336.09(A). 12 It is undisputed that Plaintiffs’ UFTA claims, which were first asserted on May 17, 2012, were brought more than four years after the transfer of Midwest.”
Helman v. Epl Prolong, Inc., 743 N.E.2d 484 (Ohio Ct. App. 2000). · cites it 3× “The parties do not dispute that count two is governed by the statute of limitations prescribed in R.C. 1336.09: “A claim for relief with respect to a transfer or an obligation that is fraudulent under section 1336.”
In Re Cincinnati Gear Co., 304 B.R. 784 (Bankr. S.D. Ohio 2003). · cites it 6× “04 and there would be a four year limitations period pursuant to Ohio Rev. Code § 1336.09(A) & (B).”
Brian Bash v. Textron Fin. Corp., 834 F.3d 651 (6th Cir. 2016). “Ohio Rev. Code § 1336.09(A). In the case of a constructive fraudulent transfer claim, the Ohio UFTA provides that the claim must be brought “within four years after the transfer was made or the obligation was incurred.”
Rieser v. Hayslip (In Re Canyon Sys. Corp.), 343 B.R. 615 (Bankr. S.D. Ohio 2006). · cites it 2× “The Code allows avoidance of only those fraudulent transfers made within one year prior to the Petition Date. See 11 U.”
Premier Therapy, L.L.C v. Childs, 2016 Ohio 7934 (Ohio Ct. App. 2016). · cites it 2× “Compare R.C. 1336.09(A) (statute of limitations for a claim under division (A)(1) of R.”
Profeta v. Lombardo, 600 N.E.2d 360 (Ohio Ct. App. 1991). · cites it 4× “The trial court concluded that Arko Auto Sales was an *624 innocent purchaser of the 1969 Pontiac GTO and, thus, its title to the GTO could not be voided under R.C. 1336.09. However, in lieu of voiding the title and based on the misrepresentation made by appellants to the…”
Locafrance United States Corp. v. Interstate Distrib. Servs., Inc., 451 N.E.2d 1222 (Ohio 1983). · cites it 3× “Appellants contend that if a fraudulent conveyance occurred, the statutes do not allow for punitive damages and attorney’s fees.”
Slone v. Lassiter (In Re Grove-Merritt), 406 B.R. 778 (Bankr. S.D. Ohio 2009). · cites it 2× “§ 548 (a)(1) and ORC § 1336.09(A) and (B). C.The Trustee’s Claim Under Code § 548(a)(1) Pertaining to the April Transfer Is Time-Barred The April Transfer occurred outside the permissible two year reach-back period for fraudulent transfer claims provided by § 548(a)(1).”
Guernsey Cty. Cmty. Dev. Corp. v. Speedy, 2023 Ohio 1796 (Ohio Ct. App. 2023). · cites it 3× “{¶31} R.C. 1336.09 provides that a claim for relief is extinguished unless an action is brought within four years after the transfer was made if utilizing R.”
Show all 57 citing cases →
— Ohio Rev. Code § 1336.09(A) — 24 cases
Bradley v. Miller, 96 F. Supp. 3d 753 (S.D. Ohio 2015). “” Ohio Rev.Code § 1336.09(A). 12 It is undisputed that Plaintiffs’ UFTA claims, which were first asserted on May 17, 2012, were brought more than four years after the transfer of Midwest.”
Brian Bash v. Textron Fin. Corp., 834 F.3d 651 (6th Cir. 2016). “Ohio Rev. Code § 1336.09(A). In the case of a constructive fraudulent transfer claim, the Ohio UFTA provides that the claim must be brought “within four years after the transfer was made or the obligation was incurred.”
Rieser v. Hayslip (In Re Canyon Sys. Corp.), 343 B.R. 615 (Bankr. S.D. Ohio 2006). “The Code allows avoidance of only those fraudulent transfers made within one year prior to the Petition Date. See 11 U.”
Helman v. Epl Prolong, Inc., 743 N.E.2d 484 (Ohio Ct. App. 2000). “The parties do not dispute that count two is governed by the statute of limitations prescribed in R.C. 1336.09: “A claim for relief with respect to 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). “§ 548 (a)(1) and ORC § 1336.09(A) and (B). C.The Trustee’s Claim Under Code § 548(a)(1) Pertaining to the April Transfer Is Time-Barred The April Transfer occurred outside the permissible two year reach-back period for fraudulent transfer claims provided by § 548(a)(1).”
— Ohio Rev. Code § 1336.09(A)(1) — 1 case
PNC Bank, N.A. v. Lewis, 2013 Ohio 5308 (Ohio Ct. App. 2013).
— Ohio Rev. Code § 1336.09(B) — 5 cases
James v. McCoy, 56 F. Supp. 2d 919 (S.D. Ohio 1998). “See Ohio Rev. Code Ann. § 1336.09 (B). For a violation of § 1336.”
In Re Cincinnati Gear Co., 304 B.R. 784 (Bankr. S.D. Ohio 2003). “04 and there would be a four year limitations period pursuant to Ohio Rev. Code § 1336.09(A) & (B).”
Weaner & Assocs., L.L.C. v. 369 W. First, L.L.C., 2020 Ohio 48 (Ohio Ct. App. 2020).
Brown Bark II, L.P. v. Coakley, 934 N.E.2d 991 (Ohio Ct. App. 2010).
In re: Omega Door Co v. (6th Cir. BAP 2009).
— Ohio Rev. Code § 1336.09(C) — 8 cases
Premier Therapy, L.L.C v. Childs, 2016 Ohio 7934 (Ohio Ct. App. 2016). “Compare R.C. 1336.09(A) (statute of limitations for a claim under division (A)(1) of R.”
In Re Cincinnati Gear Co., 304 B.R. 784 (Bankr. S.D. Ohio 2003). “04 and there would be a four year limitations period pursuant to Ohio Rev. Code § 1336.09(A) & (B).”
Fade v. Morris, 2015 Ohio 5337 (Ohio Ct. App. 2015).
James v. McCoy, 56 F. Supp. 2d 919 (S.D. Ohio 1998). “See Ohio Rev. Code Ann. § 1336.09 (B). For a violation of § 1336.”
Brown Bark II, L.P. v. Coakley, 934 N.E.2d 991 (Ohio Ct. App. 2010).
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