Ohio Revised Code

Ohio Rev. Code § 1336.10 (2026)

Laws supplementing chapter

✓ current as of May 2026
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Unless displaced by this chapter, the principles of law and equity, including, but not limited to, the law merchant and the law relating to principal and agent, estoppel, laches, fraud, misrepresentation, duress, coercion, mistake, insolvency, or other validating or invalidating cause, supplement the provisions of this chapter.

Notes of Decisions
Cited in 10 cases (1 in the last 5 years), 1964–2023 · leading case: Profeta v. Lombardo, 600 N.E.2d 360 (Ohio Ct. App. 1991).
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Profeta v. Lombardo, 600 N.E.2d 360 (Ohio Ct. App. 1991). · cites it 4× “Furthermore, the catchall provision contained in newly enacted R.C. 1336.10 2 and former R.C. 1336.11 3 states that the principles of law and equity supplement the sections in the chapter.”
Aristocrat Lakewood Nursing Home v. Mayne, 729 N.E.2d 768 (Ohio Ct. App. 1999). · cites it 3× “” R.C. 1336.10, in turn, supplements the law governing fraudulent conveyance actions with general legal principles outside the Chapter 1336 Uniform Fraudulent Transfer Act, and provides as follows: “Unless displaced by this chapter, the principles of law and equity, including,…”
Locafrance United States Corp. v. Interstate Distrib. Servs., Inc., 451 N.E.2d 1222 (Ohio 1983). · cites it 2× “Setting aside the conveyance and other remedies set forth in R.C. 1336.10 and 1336.11 would not be a sufficient deterrent to discourage appellants and other debtors from making fraudulent conveyances to avoid creditors.”
Premier Therapy, L.L.C v. Childs, 2016 Ohio 7934 (Ohio Ct. App. 2016). “” {¶131} Additionally, R.C. 1336.10 provides: “Unless displaced by this chapter, the principles of law and equity, including, but not limited to, the law merchant and the law relating to principal and agent, estoppel, laches, fraud, misrepresentation, duress, coercion, mistake,…”
Blood v. Nofzinger, 834 N.E.2d 358 (Ohio Ct. App. 2005). “Damages {¶ 59} The UFTA provides not only for the setting aside of a fraudulent transfer to the extent necessary to satisfy a debt; a creditor may also obtain “any other relief that the circumstances may require.”
Francisco A. Mateo M.D., Inc. v. Proia, 2023 Ohio 3908 (Ohio Ct. App. 2023). “” R.C. 1336.10. {¶83} The UFTA defines a creditor as a person who has a claim, a debtor as a person who is liable on a claim, and a debt as liability on a claim.”
Individual Bus. Servs. v. Carmack, 2013 Ohio 4819 (Ohio Ct. App. 2013). · cites it 2× “) {¶ 44} Finally, R.C. 1336.10 provides the following further guidance: “Unless displaced by this chapter, the principles of law and equity, including, but not limited to, the law merchant and the law relating to principal and agent, estoppel, laches, fraud, misrepresentation,…”
Yoo v. Ahn, 2018 Ohio 1291 (Ohio Ct. App. 2018). “R.C. 1336.10 supplements the law governing fraudulent conveyance actions, and provides that the principles of law and equity, including, but not limited to, the law merchant and the law relating to principal and agent, estoppel, laches, fraud, misrepresentation, duress,…”
Foster v. Gibson, 202 N.E.2d 202 (Ohio Ct. App. 1964). · cites it 2× “” *237 The relief sought by the prayer in this case is provided by Section 1336.10, Revised Code, which says: “Where a conveyance made or obligation incurred is fraudulent as to a creditor whose claim has not matured he may proceed in a court of competent jurisdiction against…”
Hamilton v. Comm'r, 61 T.C.M. 1708 (Tax Ct. 1991). “Ohio Rev. Code Ann. sec. 1336.10 . The Ohio statute defines as "fraudulent as to creditors" certain conveyances that are deemed to be fraudulent without proof of the transferor's intent.”
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