Townley
United States v. Townley
Opinion
Lead Opinion
MEMORANDUM *
Defendants Bryce and Charlene Townley appeal the district court’s grant of summary judgment in favor of the government. We affirm.
The district court did not err in holding that the Townleys transferred their real property into the Beaver Valley Trust in violation of the Washington Uniform Fraudulent Transfers Act. The Townleys’ repeated admissions that they transferred property to the Trust in order to avoid potential future creditors provide direct evidence of fraud. Further, by demonstrating that the property transfer was characterized by multiple badges of fraud, the government also showed compelling circumstantial evidence of fraud. Therefore, the government provided the requisite “clear and satisfactory proof’ that the Townleys possessed an “actual intent to hinder, delay or defraud a[ ] creditor" under the UFTA. R.C.W.A § 19.40.041(a)(1); see also Sedwick v. Gwinn, 73 Wash.App. 879 , 873 P.2d 528, 531 (1994); Clearwater v. Skyline Construction Co., Inc., 67 Wash.App. 305 , 835 P.2d 257, 264-67 (1992).
The Townleys also argue that collateral estoppel or, alternatively, res judicata precludes the government from bringing the foreclosure action altogether. This…