R.I. Gen. Laws
Rhode Island General Laws

R.I. Gen. Laws § 9-28-1 (2026)

Creditor’s equitable action

✓ current as of July 2026
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Any judgment creditor, after his or her execution has been returned wholly or in part unsatisfied, may, by a civil action in the nature of a creditor’s bill, reach and apply and subject to the payment and satisfaction of his or her judgment any equitable estate, any equitable assets, or any choses in action of the judgment debtor, except such as shall be exempt from attachment by virtue of statutory provision. The remedy provided by this section shall be cumulative and shall not supersede any existing remedy.

Notes of Decisions
Cited in 12 cases, 1976–2010 · leading case: Dionne v. Bouley, 583 F. Supp. 307 (D.R.I. 1984).
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Dionne v. Bouley, 583 F. Supp. 307 (D.R.I. 1984). · cites it 4× “On August 17, 1982, Plaintiff was served with process in a “debt on judgment” action filed by the judgment creditor pursuant to R.I.Gen.Laws § 9-28-1. This second suit sought another money judgment in the amount of $551.”
Rhode Island Hosp. v. Collins, 368 A.2d 1225 (R.I. 1977). · cites it 4× “The statutes to which we shall allude during the consideration of Collins’ appeal are: §§9-28-1, 9-28-3 through 9-28-7, and 6A-8-317(2).”
Adler v. Lincoln Hous. Auth., 623 A.2d 20 (R.I. 1993). · cites it 3× “” In addition, the trial justice denied Adler’s petition for a writ of mandamus and went on to say that “the court denies plaintiff’s prayer for a writ of mandamus and instead leaves counsel to their remedies under available statutes for supplementary proceedings, § 9-28-1 et…”
Landrigan v. McElroy, 457 A.2d 1056 (R.I. 1983). “1956 (1969 Reenactment) §§ 9-28-1 to -7; Super R.Civ.P. 69 (both outlining supplementary proceedings in aid of execution).”
Howe v. Richardson, 193 F.3d 60 (1st Cir. 1999). “R.I. Gen. Laws § 9-28-1. This provision permits an unsatisfied judgment creditor to reach “any equitable estate, any equitable assets, or any choses in action of the judgment debtor, except such as shall be exempt from attachment by virtue of statutory provision.”
Lind v. McSoley, 419 A.2d 247 (R.I. 1980). · cites it 2× “1956 (1969 Reenactment) § 9-28-1. 3 In such an action the creditor requests the estate’s executor or administrator to pay his judgment directly from the debtor’s share of the estate.”
Trainor v. Grieder, 925 A.2d 243 (R.I. 2007). · cites it 2× “A judgment creditor aggrieved by an unsatisfied execution has two options to compel payment from the debtor: institute a civil action pursuant to G.L.1956 § 9-28-1, or file an application for citation to initiate supplementary proceedings under §§ 9-28-8 through 9-28-7.”
In Re Rianna, 61 B.R. 924 (Bankr. D.R.I. 1986). · cites it 2× “LAWS § 9-28-1 (1969 Reenactment) 1 Fair-lawn brought a debt on judgment action against Rianna in the Rhode Island Fifth Division District Court (C.”
Desper v. Talbot, 727 A.2d 1233 (R.I. 1999). · cites it 4× “On September 5,1997, Evelyn filed a post judgment motion in which she sought to have the executrix Leah transfer to her all of Donald’s interest in the Franklin property and alternatively, a motion to reach and apply the Franklin property towards satisfaction of the July 25,…”
Murphy v. Charlie's Home Improvement Co., 366 A.2d 809 (R.I. 1976). · cites it 2× “Section 9-28-1, the statute authorizing supplementary proceedings, provides that “[a]ny judgment creditor * * * may by a civil action * * * reach and apply * * * any equitable estate, any equitable assets or any choses in action of the judgment debtor * * In *328 effect, an…”
Estates of Ungar Ex Rel. Strachman v. Palestinian Auth., 715 F. Supp. 2d 253 (D.R.I. 2010). “1999) (holding that § 9-28-1 permits the superior court to order a defendant executrix to execute a quit-claim deed conveying the decedent’s equity interest in Massachusetts real estate to plaintiff); id.”
Murphy v. Charlie's Home Improvement Co., Inc., 366 A.2d 809 (R.I. 1976). · cites it 2× “Section 9-28-1, the statute authorizing supplementary proceedings, provides that "[a]ny judgment creditor * * * may by a civil action * * * reach and apply * * * any equitable estate, any equitable assets or any choses in action of the judgment debtor * * *.”
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