Vt. Stat. Ann. » Title 09 Chapter 57
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 09, § 2288 (2026)

✓ current as of May 2026
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Subchapter 001 : VOIDABLE TRANSACTIONS

(Cite as: 9 V.S.A. § 2288)
Notes of Decisions
Cited in 16 cases (4 in the last 5 years), 2005–2025 · leading case: Canney v. Fisher & Strattner, LLC (In re Turner & Cook, Inc.), 507 B.R. 101 (Bankr. D. Vt. 2014).
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Canney v. Fisher & Strattner, LLC (In re Turner & Cook, Inc.), 507 B.R. 101 (Bankr. D. Vt. 2014). · cites it 7× “9 V.S.A. §§ 2288(a)(2), 2289(a); 11 U.S.C.”
Bacon v. Reimer & Braunstein, LLP, 929 A.2d 723 (Vt. 2007). · cites it 2× “As the court in Chase explained, under both the Bankruptcy Code and 9 V.S.A. §§ 2288 and 2289, a transfer may be set aside if tainted with actual fraud, requiring a showing of an actual intent to defraud a creditor, or if “constructively fraudulent,” which requires a showing,…”
Sensenich v. Molleur (In Re Chase), 328 B.R. 675 (Bankr. D. Vt. 2005). · cites it 2× “The elements of the Vermont fraudulent conveyance statute, 9 VSA §§ 2288 and 2289, are identical to § 548; the state provision allows the Trustee to obtain a monetary judgment for the difference between the debt and the value of the property as an alternative to the order…”
J.A. Morrissey, Inc. v. Smejkal, 2010 VT 66 (Vt. 2010). “Our fraudulent conveyance statute, 9 V.S.A. § 2288(a)(1), provides that “[a] transfer made or obligation incurred by a debtor is fraudulent as to a creditor .”
Astra USA, Inc. v. Bildman, 375 F. App'x 129 (2d Cir. 2010). “See Vt. Stat. Ann. tit. 9, § 2288 (b)(l)-(ll).”
Ag Venture Fin. Servs., Inc. v. Montagne (Montagne), 417 B.R. 232 (Bankr. D. Vt. 2009). “9 V.S.A. § 2288 (emphasis added). The statute thus provides two bases for finding that a transfer is fraudulent — either the debtor effected the transfer with “actual intent” to defraud a creditor, or the debtor did not receive reasonably equivalent value for the transferred…”
Huber v. Currie (Vt. Super. Ct. 2025). · cites it 19× “9 V.S.A. § 2288 (a) provides that “A transfer made or obligation incurred by a debtor is voidable as to a creditor .”
Ronald Geraw v. Pamela Geraw, 2021 VT 45 (Vt. 2021). “Based on the evidence presented thus far, and considering the factors in Vermont’s fraudulent conveyance statute, 9 V.S.A. § 2288(b), the court stated that it was considering the possibility that husband intended these transfers to hinder, delay, and defraud wife.”
Berkley Ins. Co. v. Bouchard (D. Vt. 2020). · cites it 3× “Bouchard, and for intentional and constructive fraudulent transfer pursuant to the Vermont Fraudulent Transfer Act (the “VFTA”), 9 V.S.A. §§ 2288, 2289, (Count III) against all three Defendants.”
porter v. stafford (Vt. Super. Ct. 2024). · cites it 2× “9 V.S.A. § 2288(a)(1). - The following facts are undisputed.”
Porter v. Stafford (Vt. Super. Ct. 2019). · cites it 2× “9 V.S.A. § 2288(a)(1). The following facts are undisputed.”
Green Mountain Nursing Home v. Carlisle (Vt. Super. Ct. 2012). · cites it 3× “Defendants point to their affidavits in which they state that they did not intend to defraud or deceive in accepting John’s gift.”
Show all 16 citing cases →
— Vt. Stat. Ann. tit. 09, § 2288(1)(a) — 1 case
Est. of Nancy B. Alden v. Dee (Vt. Super. Ct. 2010).
— Vt. Stat. Ann. tit. 09, § 2288(15) — 1 case
Huber v. Currie (Vt. Super. Ct. 2025). “9 V.S.A. § 2288 (a) provides that “A transfer made or obligation incurred by a debtor is voidable as to a creditor .”
— Vt. Stat. Ann. tit. 09, § 2288(a) — 1 case
Bacon v. Reimer & Braunstein, LLP, 929 A.2d 723 (Vt. 2007). “As the court in Chase explained, under both the Bankruptcy Code and 9 V.S.A. §§ 2288 and 2289, a transfer may be set aside if tainted with actual fraud, requiring a showing of an actual intent to defraud a creditor, or if “constructively fraudulent,” which requires a showing,…”
— Vt. Stat. Ann. tit. 09, § 2288(a)(1) — 6 cases
J.A. Morrissey, Inc. v. Smejkal, 2010 VT 66 (Vt. 2010). “Our fraudulent conveyance statute, 9 V.S.A. § 2288(a)(1), provides that “[a] transfer made or obligation incurred by a debtor is fraudulent as to a creditor .”
Huber v. Currie (Vt. Super. Ct. 2025). “9 V.S.A. § 2288 (a) provides that “A transfer made or obligation incurred by a debtor is voidable as to a creditor .”
porter v. stafford (Vt. Super. Ct. 2024). “9 V.S.A. § 2288(a)(1). - The following facts are undisputed.”
Porter v. Stafford (Vt. Super. Ct. 2019). “9 V.S.A. § 2288(a)(1). The following facts are undisputed.”
Berkley Ins. Co. v. Bouchard (D. Vt. 2020). “Bouchard, and for intentional and constructive fraudulent transfer pursuant to the Vermont Fraudulent Transfer Act (the “VFTA”), 9 V.S.A. §§ 2288, 2289, (Count III) against all three Defendants.”
— Vt. Stat. Ann. tit. 09, § 2288(a)(2) — 2 cases
Canney v. Fisher & Strattner, LLC (In re Turner & Cook, Inc.), 507 B.R. 101 (Bankr. D. Vt. 2014). “9 V.S.A. §§ 2288(a)(2), 2289(a); 11 U.S.C.”
Huber v. Currie (Vt. Super. Ct. 2025). “9 V.S.A. § 2288 (a) provides that “A transfer made or obligation incurred by a debtor is voidable as to a creditor .”
— Vt. Stat. Ann. tit. 09, § 2288(a)(2)(A) — 1 case
Huber v. Currie (Vt. Super. Ct. 2025). “9 V.S.A. § 2288 (a) provides that “A transfer made or obligation incurred by a debtor is voidable as to a creditor .”
— Vt. Stat. Ann. tit. 09, § 2288(a)(2)(B) — 1 case
Huber v. Currie (Vt. Super. Ct. 2025). “9 V.S.A. § 2288 (a) provides that “A transfer made or obligation incurred by a debtor is voidable as to a creditor .”
— Vt. Stat. Ann. tit. 09, § 2288(b) — 2 cases
Ronald Geraw v. Pamela Geraw, 2021 VT 45 (Vt. 2021). “Based on the evidence presented thus far, and considering the factors in Vermont’s fraudulent conveyance statute, 9 V.S.A. § 2288(b), the court stated that it was considering the possibility that husband intended these transfers to hinder, delay, and defraud wife.”
Green Mountain Nursing Home v. Carlisle (Vt. Super. Ct. 2012). “Defendants point to their affidavits in which they state that they did not intend to defraud or deceive in accepting John’s gift.”
— Vt. Stat. Ann. tit. 09, § 2288(b)(1) — 1 case
Berkley Ins. Co. v. Bouchard (D. Vt. 2020). “Bouchard, and for intentional and constructive fraudulent transfer pursuant to the Vermont Fraudulent Transfer Act (the “VFTA”), 9 V.S.A. §§ 2288, 2289, (Count III) against all three Defendants.”
— Vt. Stat. Ann. tit. 09, § 2288(b)(5) — 2 cases
porter v. stafford (Vt. Super. Ct. 2024). “9 V.S.A. § 2288(a)(1). - The following facts are undisputed.”
Porter v. Stafford (Vt. Super. Ct. 2019). “9 V.S.A. § 2288(a)(1). The following facts are undisputed.”
— Vt. Stat. Ann. tit. 09, § 2288(b)(9) — 1 case
Huber v. Currie (Vt. Super. Ct. 2025). “9 V.S.A. § 2288 (a) provides that “A transfer made or obligation incurred by a debtor is voidable as to a creditor .”
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