Wash. Rev. Code » Title 19 · Chapter 19.40
Revised Code of Washington

Wash. Rev. Code § 19.40.071 (2026)

Remedies of creditors

✓ current as of May 2026
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(1) In an action for relief against a transfer or obligation under this chapter, a creditor, subject to the limitations in RCW 19.40.081, may obtain:
(a) Avoidance of the transfer or obligation to the extent necessary to satisfy the creditor's claim;
(b) An attachment or other provisional remedy against the asset transferred or other property of the transferee if available under applicable law; and
(c) Subject to applicable principles of equity and in accordance with applicable rules of civil procedure:
(i) An injunction against further disposition by the debtor or a transferee, or both, of the asset transferred or of other property;
(ii) Appointment of a receiver to take charge of the asset transferred or of other property of the transferee; or
(iii) Any other relief the circumstances may require.
(2) 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.
[ 2017 c 57 s 7; 2000 c 171 s 54; 1987 c 444 s 7.]

Notes:

Effective date—1987 c 444: See note following RCW 19.40.011.
Notes of Decisions
Cited in 22 cases (6 in the last 5 years), 1992–2025 · leading case: Thompson v. Hanson, 239 P.3d 537 (Wash. 2009).
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Thompson v. Hanson, 239 P.3d 537 (Wash. 2009). · cites it 2× “RCW 19.40.071, .081. However, the statute only allows “the creditor [to] recover judgment for the value of the asset transferred, as adjusted under subsection (c) of this section, or the amount necessary to satisfy the creditor’s claim, whichever is less.”
Calvert v. Erdman (In re Nw. Territorial Mint, LLC), 591 B.R. 852 (Bankr. W.D. Wash. 2018). · cites it 4× “Erdmann is neither a transferee nor an obligee, since she did not receive any of the Transfers and none of the Transfers created an obligation to her.”
Clearwater v. Skyline Constr. Co., 835 P.2d 257 (Wash. Ct. App. 1992). · cites it 2× “See RCW 19.40.071. Thus, the Clearwaters' attachment of the property cannot be said to be wrongful.”
Assocs. Hous. Fin. v. Stredwick, 83 P.3d 1032 (Wash. Ct. App. 2004). · cites it 4× “See RCW 19.40.071 (a creditor may seek avoidance of the transfer); RCW 19.”
Thompson v. Hanson, 174 P.3d 120 (Wash. Ct. App. 2007). “(b) Except as otherwise provided in this section, to the extent a transfer is voidable in an action by a creditor under RCW 19.40.071(a)(1), the creditor may recover judgment for the value of the asset transferred, as adjusted under subsection (c) of this section, or the amount…”
Thompson v. Hanson, 142 Wash. App. 53 (Wash. Ct. App. 2007). “(b) Except as otherwise provided in this section, to the extent a transfer is voidable in an action by a creditor under RCW 19.40.071(a)(1), the creditor may recover judgment for the value of the asset transferred, as adjusted under subsection (c) of this section, or the amount…”
Douglas v. Hill, 199 P.3d 493 (Wash. Ct. App. 2009). · cites it 2× “RCW 19.40.071 permits a creditor to void "the transfer or obligation to the extent necessary to satisfy the creditor's claim.”
Douglas v. Hill, 148 Wash. App. 760 (Wash. Ct. App. 2009). · cites it 2× “RCW 19.40.071 permits a creditor to void “the transfer or obligation to the extent necessary to satisfy the creditor’s claim.”
Eagle Pac. Ins. v. Christensen Motor Yacht Corp., 934 P.2d 715 (Wash. Ct. App. 1997). “The judgment may be entered against: (1) The first transferee of the asset or the person for whose benefit the transfer was made .”
Thompson v. Hanson, 239 P.3d 537 (Wash. 2010). · cites it 2× “RCW 19.40.071, .081. However, the statute only allows "the creditor [to] recover judgment for the value of the asset transferred, as adjusted under subsection (c) of this section, or the amount necessary to satisfy the creditor's claim, whichever is less.”
Thompson v. Hanson, 219 P.3d 659 (Wash. 2009). “(b) Except as otherwise provided in this section, to the extent a transfer is voidable in an action by a creditor under RCW 19.40.071(a)(1), the creditor may recover judgment for the value of the asset transferred, as adjusted under subsection (c) of this section, or the amount…”
Assocs. Hous. Fin. L.L.C. v. Stredwick, 120 Wash. App. 52 (Wash. Ct. App. 2004). · cites it 4× “See RCW 19.40.071 (a creditor may seek avoidance of the transfer); RCW 19.”
Show all 22 citing cases →
— Wash. Rev. Code § 19.40.071(1) — 1 case
Kenneth Wren, et ux. v. Stanford & Sons, LLC (Wash. Ct. App. 2025).
— Wash. Rev. Code § 19.40.071(1)(b) — 1 case
Vaughn v. Cohen (W.D. Wash. 2024).
— Wash. Rev. Code § 19.40.071(a) — 4 cases
Calvert v. Erdman (In re Nw. Territorial Mint, LLC), 591 B.R. 852 (Bankr. W.D. Wash. 2018). “Erdmann is neither a transferee nor an obligee, since she did not receive any of the Transfers and none of the Transfers created an obligation to her.”
Assocs. Hous. Fin. v. Stredwick, 83 P.3d 1032 (Wash. Ct. App. 2004). “See RCW 19.40.071 (a creditor may seek avoidance of the transfer); RCW 19.”
Assocs. Hous. Fin. L.L.C. v. Stredwick, 120 Wash. App. 52 (Wash. Ct. App. 2004). “See RCW 19.40.071 (a creditor may seek avoidance of the transfer); RCW 19.”
John Shubeck, Shelly Williams, V Catherine Shubeck (Wash. Ct. App. 2021).
— Wash. Rev. Code § 19.40.071(a)(1) — 12 cases
Thompson v. Hanson, 239 P.3d 537 (Wash. 2009). “RCW 19.40.071, .081. However, the statute only allows “the creditor [to] recover judgment for the value of the asset transferred, as adjusted under subsection (c) of this section, or the amount necessary to satisfy the creditor’s claim, whichever is less.”
Thompson v. Hanson, 174 P.3d 120 (Wash. Ct. App. 2007). “(b) Except as otherwise provided in this section, to the extent a transfer is voidable in an action by a creditor under RCW 19.40.071(a)(1), the creditor may recover judgment for the value of the asset transferred, as adjusted under subsection (c) of this section, or the amount…”
Thompson v. Hanson, 142 Wash. App. 53 (Wash. Ct. App. 2007). “(b) Except as otherwise provided in this section, to the extent a transfer is voidable in an action by a creditor under RCW 19.40.071(a)(1), the creditor may recover judgment for the value of the asset transferred, as adjusted under subsection (c) of this section, or the amount…”
Calvert v. Erdman (In re Nw. Territorial Mint, LLC), 591 B.R. 852 (Bankr. W.D. Wash. 2018). “Erdmann is neither a transferee nor an obligee, since she did not receive any of the Transfers and none of the Transfers created an obligation to her.”
Eagle Pac. Ins. v. Christensen Motor Yacht Corp., 934 P.2d 715 (Wash. Ct. App. 1997). “The judgment may be entered against: (1) The first transferee of the asset or the person for whose benefit the transfer was made .”
— Wash. Rev. Code § 19.40.071(a)(2) — 2 cases
Assocs. Hous. Fin. v. Stredwick, 83 P.3d 1032 (Wash. Ct. App. 2004). “See RCW 19.40.071 (a creditor may seek avoidance of the transfer); RCW 19.”
Assocs. Hous. Fin. L.L.C. v. Stredwick, 120 Wash. App. 52 (Wash. Ct. App. 2004). “See RCW 19.40.071 (a creditor may seek avoidance of the transfer); RCW 19.”
— Wash. Rev. Code § 19.40.071(a)(3)(iii) — 1 case
John Shubeck, Shelly Williams, V Catherine Shubeck (Wash. Ct. App. 2021).
— Wash. Rev. Code § 19.40.071(b) — 2 cases
Assocs. Hous. Fin. v. Stredwick, 83 P.3d 1032 (Wash. Ct. App. 2004). “See RCW 19.40.071 (a creditor may seek avoidance of the transfer); RCW 19.”
Assocs. Hous. Fin. L.L.C. v. Stredwick, 120 Wash. App. 52 (Wash. Ct. App. 2004). “See RCW 19.40.071 (a creditor may seek avoidance of the transfer); RCW 19.”
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