United States Third Circuit

Summary judgment for plaintiff-former wife on her claim that defendant-former husband's transfer of a parcel of real estate to himself and his new wife as tenants by the entirety violated the Pennsylvania Uniform Fraudulent Transfer Act (PUFTA), and the district court's accompanying orders, are affirmed, where: 1) defendant's action constituted an actual fraudulent transfer as well as a constructive fraudulent transfer in an attempt to avoid his spousal and child support obligations; and 2) when, as here, a plaintiff can show outrageous conduct coupled with a fraudulent transfer, a court may award punitive damages as a form of any other relief the circumstances may require under PUFTA.

Appellate Information

• Decided 09/03/2013
• Published 09/03/2013

Judges

• COWEN

Court

• United States Third Circuit

Counsel