This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Plaintiff sought to set aside a property transfer from the Defendant to his wife, alleging it was a fraudulent conveyance under the Uniform Fraudulent Transfer Act (UFTA). The Defendant sold the property to his wife in January 1990, and the deed was recorded shortly thereafter. The Federal Deposit Insurance Corporation (FDIC) obtained a judgment against the Defendant in 1991 for defaulting on a promissory note. The judgment was later assigned to the Plaintiff in 1993, who filed the action in 1994 (paras 1-4).
Procedural History
- District Court of Bernalillo County: The court dismissed the Plaintiff's complaint, finding that the statute of limitations under the UFTA had expired (para 1).
Parties' Submissions
- Plaintiff-Appellant: Argued that the four-year limitation period under the UFTA should begin from the date of the FDIC's judgment in 1991 or from the date the assignment of judgment was recorded in 1993, making the 1994 filing timely (paras 6-7).
- Defendants-Appellees: Contended that the action was barred by the UFTA's statute of limitations, as the four-year period began in 1990 when the property transfer was recorded, and the one-year discovery period began when the Plaintiff could have reasonably discovered the transfer in 1993 (paras 4, 10, 14).
Legal Issues
- Whether the Plaintiff's action to set aside the property transfer was barred by the statute of limitations under the UFTA.
Disposition
- The Court of Appeals affirmed the dismissal of the Plaintiff's complaint (para 15).
Reasons
Per Bustamante J. (Apodaca CJ. and Donnelly J. concurring):
The court held that the UFTA's statute of limitations extinguished the Plaintiff's claim. The four-year period began in January 1990 when the property transfer was recorded, and it expired in January 1994. The Plaintiff's argument that the period should start from the FDIC's judgment in 1991 or the assignment's recording in 1993 was rejected, as the statute's plain language ties the limitation period to the date of the transfer (paras 6-8).
The court also found that the one-year discovery period began when the Plaintiff could have reasonably discovered the transfer. Since the transfer was publicly recorded, the Plaintiff, as a reasonably prudent entity, should have discovered it upon acquiring the judgment in May 1993. Thus, the one-year period expired in May 1994, and the July 1994 filing was untimely (paras 10-14).
The court emphasized that the UFTA operates as a statute of repose, extinguishing claims after the specified period regardless of when the cause of action accrues. This ensures finality in property transactions (paras 9-10).