Wisconsin Statutes

Wis. Stat. § 242.07 (2026)

Remedies of creditors

✓ current as of July 2026
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242.07242.07Remedies of creditors.
242.07(1)(1)In an action for relief against a transfer or obligation under this chapter, a creditor, subject to the limitations in s. 242.08, may obtain any of the following:
242.07(1)(a)(a) Avoidance of the transfer or obligation to the extent necessary to satisfy the creditor’s claim.
242.07(1)(b)(b) An attachment or other provisional remedy against the asset transferred or other property of the transferee if available under chs. 810 to 813 or other applicable law.
242.07(1)(c)(c) Subject to applicable principles of equity and in accordance with applicable rules of civil procedure:
242.07(1)(c)1.1. An injunction against further disposition by the debtor or a transferee, or both, of the asset transferred or of other property;
242.07(1)(c)2.2. Appointment of a receiver to take charge of the asset transferred or of other property of the transferee; or
242.07(1)(c)3.3. Any other relief the circumstances may require.
242.07(2)(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.
242.07 HistoryHistory: 1987 a. 192; 2023 a. 246.
242.07 AnnotationNothing in ch. 242 changes the principle of law that compensatory damages are a threshold requirement for awarding punitive damages or otherwise permits a punitive damages award. Rescission under sub. (1) is an equitable remedy and does not constitute compensatory damages. C & A Investments v. Kelly, 2010 WI App 151, 330 Wis. 2d 223, 792 N.W.2d 644, 09-2420.
Notes of Decisions
Cited in 32 cases (4 in the last 5 years), 1930–2026 · leading case: Penny L. Springer v. Nohl Elec. Prods. Corp., 912 N.W.2d 1 (Wis. 2018).
Penny L. Springer v. Nohl Elec. Prods. Corp., 912 N.W.2d 1 (Wis. 2018). · cites it 9× “§ 242.07 (1)(a)), attach the asset in the hands of the transferee (§ 242.”
Int'l Ass'n of MacHinists & Aerospace Workers v. United States Can Co., 441 N.W.2d 710 (Wis. 1989). · cites it 6× “Can acquisition of the Continental packaging sector have been made to hinder, delay, or defraud plaintiffs, who are both present and future *508 creditors of defendants, within the meaning of Section 7 of the Uniform Fraudulent Conveyance Act, Wis. Stat. § 242.07 . Consequently,…”
C & A Investments v. Kelly, 2010 WI App 151 (Wis. Ct. App. 2010). · cites it 6× “Punitive damages are not expressly listed among the enumerated remedies in Wis. Stat. § 242.07 (1). When the legislature provides a comprehensive statutory remedy, absent some indication to the contrary, the statutory remedy is deemed to be exclusive.”
Borne v. Gonstead Advanced Techniques, Inc., 2003 WI App 135 (Wis. Ct. App. 2003). · cites it 3× “As relief, the Trust requested "avoidance" of the transfer of GAT's assets, pursuant to Wis. Stat. § 242.07 (1)(a) that *260 provides creditors' remedies; 4 judicial dissolution pursuant to Wis.”
Marriage of Poindexter v. Poindexter, 419 N.W.2d 223 (Wis. 1988). · cites it 2× “2d 356 (1958); sec. 242.07, Stats. [4] "766.31(8) Classification of property of spouses.”
Caldwell v. Caldwell, 92 N.W.2d 356 (Wis. 1958). · cites it 2× “” Here the court found, on ample evidence, that the transfer of stocks was made with actual intent to hinder, delay, and defraud Vivian and the minor child.”
Crown Castle USA, Inc. v. Orion Constr. Grp., LLC, 2012 WI 29 (Wis. 2012). “See § 242.07. Alternatively or additionally, the judgment creditor could commence a garnishment action against the non-judgment debtor third party under § 812.”
Dubis v. B.W. Supply (In Re Delta Grp.), 300 B.R. 918 (Bankr. E.D. Wis. 2003). · cites it 2× “Subject to certain defenses (modeled after the defenses in Section 547(c) of the Bankruptcy Code), Wis. Stat. § 242.07 allows “a creditor” to avoid a transfer described in § 242.”
Beck v. BidRX, LLC, 918 N.W.2d 96 (Wis. Ct. App. 2018). “§ 242.07 gives the court broad equitable authority when assets have been fraudulently transferred.”
Armour-Dial, Inc. v. Alkar Eng'g Corp., 469 F. Supp. 1198 (E.D. Wis. 1979). “, nor intentionally fraudulent, see § 242.07, Wis.Stats. Since the plaintiff has not raised a genuine issue for trial as to the applicability of any exception to the general rule of non-liability of a corporation which purchases the assets of another corporation, Alkar-DEC’s…”
Off. Comm. of Unsecured Creditors of Great Lakes Quick Lube LP v. Theisen, 920 N.W.2d 356 (Wis. Ct. App. 2018). “§ 242.07(1)(a) creates remedies for defrauded creditors, including "[a]voidance of the transfer or obligation to the extent necessary to satisfy the creditor's claim.”
Badger State Bank v. Taylor, 2004 WI App 17 (Wis. Ct. App. 2003). · cites it 2× “4 See Wis. Stat. §242.07 (1) (providing that a prevailing creditor may "avoid[ ].”
— Wis. Stat. § 242.07(1) — 1 case
C & A Investments v. Kelly, 2010 WI App 151 (Wis. Ct. App. 2010). “Punitive damages are not expressly listed among the enumerated remedies in Wis. Stat. § 242.07 (1). When the legislature provides a comprehensive statutory remedy, absent some indication to the contrary, the statutory remedy is deemed to be exclusive.”
— Wis. Stat. § 242.07(1)(a) — 2 cases
Borne v. Gonstead Advanced Techniques, Inc., 2003 WI App 135 (Wis. Ct. App. 2003). “As relief, the Trust requested "avoidance" of the transfer of GAT's assets, pursuant to Wis. Stat. § 242.07 (1)(a) that *260 provides creditors' remedies; 4 judicial dissolution pursuant to Wis.”
Off. Comm. of Unsecured Creditors of Great Lakes Quick Lube LP v. Theisen, 920 N.W.2d 356 (Wis. Ct. App. 2018). “§ 242.07(1)(a) creates remedies for defrauded creditors, including "[a]voidance of the transfer or obligation to the extent necessary to satisfy the creditor's claim.”
— Wis. Stat. § 242.07(1)(b) — 3 cases
Penny L. Springer v. Nohl Elec. Prods. Corp., 912 N.W.2d 1 (Wis. 2018). “§ 242.07 (1)(a)), attach the asset in the hands of the transferee (§ 242.”
— Wis. Stat. § 242.07(1)(c) — 1 case
Penny L. Springer v. Nohl Elec. Prods. Corp., 912 N.W.2d 1 (Wis. 2018). “§ 242.07 (1)(a)), attach the asset in the hands of the transferee (§ 242.”
— Wis. Stat. § 242.07(2) — 1 case
Penny L. Springer v. Nohl Elec. Prods. Corp., 912 N.W.2d 1 (Wis. 2018). “§ 242.07 (1)(a)), attach the asset in the hands of the transferee (§ 242.”
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