Timothy v. Pia Anderson Dorius Reynard Moss, 2019 UT 69 (Dec. 16, 2019)

The supreme court “granted certiorari in this case to address whether a law firm that deposited funds from a client into its trust account is a ‘transferee’ under the” Uniform Fraudulent Transfer Act.  The court of appeals had answered the question in the negative.  The supreme court, however, did not reach the issue because while the appeal was pending, the petitioners allowed the judgment from the trial court to expire.  Upon expiration of the judgment, the plaintiffs no longer had a right to payment under the judgment, thereby depriving them of status as a creditor, which is required for a UFTA claim.  Because the judgment expired prior to the court of appeals issuing its opinion, the supreme court vacated the court of appeals’ decision as well.