Vermont Statutes Annotated

Vt. Stat. Ann. tit. 09, § 2291 (2026)

✓ current as of May 2026

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Subchapter 001 : VOIDABLE TRANSACTIONS

(Cite as: 9 V.S.A. § 2291)

§ 2291. Remedies of creditor

(a) In an action for relief against a transfer or obligation under this chapter, a creditor, subject to the limitations in section 2292 of this title, may obtain:

(1) avoidance of the transfer or obligation to the extent necessary to satisfy the creditor’s claim;

(2) an attachment or other provisional remedy against the asset transferred or other property of the transferee in accordance with the procedure prescribed by the Vermont Rules of Civil Procedure;

(3) subject to applicable principles of equity and in accordance with applicable Rules of Civil Procedure:

(A) an injunction against further disposition by the debtor or a transferee, or both, of the asset transferred or of other property;

(B) appointment of a receiver to take charge of the asset transferred or of other property of the transferee; or

(C) any other relief the circumstances may require.

(b) If a creditor has obtained a judgment on a claim against the debtor, the creditor, if the court so orders, may levy execution on the asset transferred or its proceeds. (Added 1995, No. 179 (Adj. Sess.), § 14; amended 2017, No. 20, § 1.)

Notes of Decisions

Cited in 3 cases (1 in the last 5 years), 2014–2024 · 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). “A trustee may avoid and recover constructive fraudulent transfers made within four years of the petition date if acting pursuant to Vermont law, and within two years if acting pursuant to federal law.”

porter v. stafford (Vt. Super. Ct. 2024). “” 9 V.S.A. § 2291(a)(1); see also id. § 2292(a) (“A transfer or obligation is not voidable under subdivision 2288(a)(1) of this title against a person who took in good faith and for a reasonably equivalent value or against any subsequent transferee or obligee.”

Porter v. Stafford (Vt. Super. Ct. 2019). “” 9 V.S.A. § 2291(a)(1); see also id. § 2292(a) (“A transfer or obligation is not voidable under subdivision 2288(a)(1) of this title against a person who took in good faith and for a reasonably equivalent value or against any subsequent transferee or obligee.”

— Vt. Stat. Ann. tit. 09, § 2291(a)(1) — 2 cases

porter v. stafford (Vt. Super. Ct. 2024). “” 9 V.S.A. § 2291(a)(1); see also id. § 2292(a) (“A transfer or obligation is not voidable under subdivision 2288(a)(1) of this title against a person who took in good faith and for a reasonably equivalent value or against any subsequent transferee or obligee.”

Porter v. Stafford (Vt. Super. Ct. 2019). “” 9 V.S.A. § 2291(a)(1); see also id. § 2292(a) (“A transfer or obligation is not voidable under subdivision 2288(a)(1) of this title against a person who took in good faith and for a reasonably equivalent value or against any subsequent transferee or obligee.”

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