Motorola Solutions v. Pick CA2/5

INTRODUCTION

In 2014, plaintiff and respondent Motorola Solutions, Inc. (Motorola) sued defendants and appellants Harold Pick; his mother, Ann Pick; and his friend Jay Francis under the Uniform Voidable Transactions Act (Civ. Code, § 3439 et seq.) (UVTA or Act).1 Motorola claimed the trio had schemed to buy Ann a house with $250,000 of Harold’s money, thereby preventing Motorola from seizing those funds to collect on a judgment. At trial, the jury concluded that although Harold had indeed concealed the funds, Ann and Francis were good faith transferees for value, and Motorola could not void the sale. The jury separately found Harold had committed fraud by concealment, which had not been separately pled in the complaint, and awarded Motorola $250,504 in damages. At the subsequent bench trial on declaratory and equitable relief, the trial court reformed the deed to the house to grant Motorola a share of the property proportionate to the money Harold had given Ann—namely, the damages the jury had awarded for the concealment claim. Although appellants collectively raised more than a dozen issues on appeal, we find one dispositive: The jury did not reach a verdict on every element of…