Vermont Statutes Annotated

Vt. Stat. Ann. tit. 09, § 2281 (2026)

✓ current as of May 2026
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Subchapter 001 : VOIDABLE TRANSACTIONS

(Cite as: 9 V.S.A. § 2281)
Notes of Decisions
Cited in 12 cases (1 in the last 5 years), 1969–2026 · leading case: Unsecured Creditors Comm. of Debtor v. Noyes (In Re STN Enter., Inc.), 73 B.R. 470 (Bankr. D. Vt. 1987).
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Unsecured Creditors Comm. of Debtor v. Noyes (In Re STN Enter., Inc.), 73 B.R. 470 (Bankr. D. Vt. 1987). · cites it 2× “9 V.S.A. § 2281; Becker v. Becker, 138 Vt.”
Clayton v. Clayton, 569 A.2d 1077 (Vt. 1989). · cites it 2× “made or had to avoid a right, debt or duty of another person, shall, as against the party only whose right, debt or duty is attempted to be avoided, his heirs, executors, administrators and assigns, be null and void.”
Becker v. Becker, 416 A.2d 156 (Vt. 1980). “The plaintiff contends that she is entitled to a declaration that the defendant fraudulently conveyed his fee interest in certain Ferrisburg, Vermont, real estate to himself and his second wife in hindrance of the plaintiff’s ability to recover on the defendant’s debt to her.”
In Re Farrar, 219 B.R. 48 (Bankr. D. Vt. 1998). · cites it 3× ““It [wa]s patently obvious to [the Family Court] that the conveyance was made in an effort to deprive the defendant of any share in this marital asset,” and the Court refused to “condone such a superficial ploy,” finding the conveyance “unenforceable as a fraudulent transfer”…”
Imported Car Ctr., Inc. v. Billings, 653 A.2d 765 (Vt. 1994). “” The court further instructed the jury that to prevail on its claim of fraudulent conveyance, plaintiff must prove four elements: (1) defendant Dorothy Billings owed a right, debt, or duty to plaintiff, (2) *81 defendant conveyed property that was subject to execution in…”
State Bank of Albany v. Martinez (In Re Martinez), 31 B.R. 299 (Bankr. D. Vt. 1983). · cites it 2× “It alleges *300 that under the Vermont Fraudulent Conveyance Act, 9 V.S.A. § 2281, et seq., fraudulent and deceitful conveyances of property to avoid a debt are null and void as to the creditor, and the trustee in bankruptcy, under § 544(b) of the Bankruptcy Code, may avoid any…”
Bray Enter., Inc. v. First Vermont Bank & Trust Co. (In Re Bray Enter., Inc.), 38 B.R. 75 (Bankr. D. Vt. 1984). “The Bank has not met its burden of proof under the fraudulent conveyances statute, 9 V.S.A. § 2281, and has failed to establish that, on the date of the filing of the petition, Bray had no interest in the proceeds of the sale of the snowgroomer.”
Stevens v. Hart, 356 A.2d 499 (Vt. 1976). “The action was brought under 9 V.S.A. § 2281 to set aside a conveyance between the defendants as fraudulent as to the plaintiffs as attaching judgment creditors.”
Klein v. Wolf Run Resort, Inc., 659 A.2d 1153 (Vt. 1995). “1991) (word “void” in 9 V.S.A. § 2281 means “voidable”). The penalty provision states that an invalid loan “shall be void and the lender shall have no right to collect or receive any principal, interest, or charges whatsoever.”
Russell v. Roberts, 254 A.2d 587 (Vt. 1969). · cites it 5× “Under 9 V.S.A. §2281 and the cases decided thereunder, the alleged victim of a tort is not a party aggrieved under the Statute and an alleged claim sounding in tort is not a “right, debt or duty” within the meaning of the Statute.”
Vecchiarino v. Ridgway (Vt. Super. Ct. 2026). “See 9 V.S.A. § 2281 et seq. Fraud is not the only way to show that the Court should pierce the corporate veil.”
Pnc Bank, Nat'l Ass'n v. Robert B. Millman & Mark Fleischman, 164 F.3d 785 (2d Cir. 1999). “9 V.S.A. § 2281. 6 . Section 511 provides: A civil action, except one brought upon the judgment or decree of a court of record of the United States or of this or some other state, and except as otherwise provided, shall be commenced within six years after the cause of action…”
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