United States v. Badger — F.3d —-, 2016 WL 1169416 (10th Cir. Mar. 25, 2016)

Although acknowledging that the Utah Supreme Court has never recognized a reverse-piercing claim, the court predicted that Utah courts would apply reverse veil-piercing against corporate defendants to hold them liable as alter egos of the defendant, who failed to pay a consent judgment under which he agreed to disgorge profits from a securities fraud scheme.