Rolloffs Hawaii, LLC - Adversary Proceeding

United States Bankruptcy Court, D. Hawaii·Decided October 21, 2021·No. 18-90035·Unknown

Opinion

Date Signed: October 21, 2021 Ay ii . >, SO ORDERED.

Wey Robert J. Faris Ser oF ge United States Bankruptcy Judge

UNITED STATES BANKRUPTCY COURT

DISTRICT OF HAWATI

In re: Case No. 16-01294 Chapter 7 ROLLOFFS HAWAII, LLC,

Debtor. Adv. Pro. No. 18-90035 DANE S. FIELD, Chapter 7 Trustee, Dkt. 71 Plaintiff,

vs.

TRASHMASTERS, LLC, et al.

Defendants.

FINDINGS OF FACT AND CONCLUSIONS OF LAW ON FRAUDULENT TRANSFER CLAIMS

The trial in this adversary proceeding was held on September 14-17,

2021. At trial, Enver Painter, Simon Klevansky, and Carisa Lima Ka’ala

Duffy represented plaintiff Dane S. Field, chapter 7 trustee of Rolloffs

Hawaii, LLC, and Brett R. Tobin represented defendant Rolloffs Hawaii, Inc. Kristian Gourlay attempted to represent defendant The KNG Group,

LLC, but the court did not permit him to do so, pursuant to Local Rule 81.1(b), because he is not a licensed attorney.

All claims against all other parties were dismissed before trial. The claims in the first amended complaint (ECF 71) that remain for decision are

counts 5-8 and 21-24 against Rolloffs Hawaii, Inc., and counts 25-32 against The KNG Group, Inc.

I. APPLICABLE LAW A. Section 544(b)

Section 544(b) of the Bankruptcy Code provides that, subject to an exception that is not applicable here, “the trustee may avoid any transfer of

an interest of the debtor in property or any obligation incurred by the debtor that is voidable under applicable law by a creditor holding an

[allowable] unsecured claim . . .” Section 544(b) allows the trustee to step

2 into the shoes of an actual creditor of the debtor and assert avoidance

claims that the creditor could bring. Under section 544(b), the trustee must identify an actual creditor

holding an allowable claim against the debtor that could have asserted avoidance claims.

B. HUFTA and FDCPA In this case, the trustee employs section 544(b) to claim that certain

transfers and obligations are avoidable under the Hawaii Uniform Fraudulent Transfers Act (“HUFTA,” Haw. Rev. Stat. ch. 651C) and the

Federal Debt Collections Procedure Act (“FDCPA,” 28 U.S.C. §§ 3001-3308). HUFTA and FDCPA create claims that are identical in substance.

The trustee relies on three pairs of provisions of HUFTA and FDCPA.1

1 The first amended complaint does not state claims under Haw. Rev. Stat. § 651C- 5(b) or its FDCPA counterpart, 28 U.S.C. § 3304(a)(2).

3 1. Intentional Fraudulent Transfers

The first is Haw. Rev. Stat. § 651C-4(a)(1), which applies to intentional fraudulent transfers:

A transfer made or obligation incurred by a debtor is fraudulent as to a creditor, whether the creditor’s claim arose before or after the transfer was made or the obligation was incurred, if the debtor made the transfer or incurred the obligation . . . with actual intent to hinder, delay, or defraud any creditor of the debtor . . .

28 U.S.C. § 3304(b)(1)(A) is identical in substance. These sections codify the common law of fraudulent conveyances, which originated in the Statute of 13 Elizabeth I (1570) and remains good law in Hawaii, Achiles v. Cajigal, 39 Haw. 493 (1952). HUFTA and FDCPA provide substantively identical lists of

circumstantial factors that a court may employ to ascertain the debtor’s intent. Haw. Rev. Stat. § 651C-4(b); 28 U.S.C. § 3304(b)(2).

2. Constructive Fraudulent Transfers The second pair of provisions on which the trustee relies is Haw. Rev.

Stat. § 651C-4(a)(2) and 28 U.S.C. § 3304(b)(1)(B). These provisions apply to 4 one type of so-called “constructive” fraudulent transfers, meaning transfers

that are avoidable based largely on the objective circumstances and effects of the transfers, and without proof of actual intent to hinder, delay, or

defraud creditors. Specifically, Haw. Rev. Stat. § 651C-4(a) provides that: A transfer made or obligation incurred by a debtor is fraudulent as to a creditor, whether the creditor's claim arose before or after the transfer was made or the obligation was incurred, if the debtor made the transfer or incurred the obligation:

* * *

(2) Without receiving a reasonably equivalent value in exchange for the transfer or obligation, and the debtor:

(A) Was engaged or was about to engage in a business or a transaction for which the remaining assets of the debtor were unreasonably small in relation to the business or transaction; or

(B) Intended to incur, or believed or reasonably should have believed that the debtor would incur, debts beyond the debtor's ability to pay as they became due.

The third provision on which the trustee relies is Haw. Rev. Stat. § 651C-5(a), which creates another constructive fraudulent transfer claim: 5 A transfer made or obligation incurred by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation without receiving a reasonably equivalent value in exchange for the transfer or obligation and the debtor was insolvent at that time or the debtor becomes insolvent as a result of the transfer or obligation.

This is identical in substance to 28 U.S.C. § 3304(a)(1). 3. “Transfer” and “Obligation” Defined The statutes define “transfer” broadly. The word means “every mode, direct or indirect, absolute or conditional, voluntary or involuntary, of disposing of or parting with an asset or an interest in an asset, and

includes a payment of money, a release, a lease, and the creation of a lien or encumbrance.” Haw. Rev. Stat. § 651C-1; see also 28 U.S.C. § 3301(6).

Neither HUFTA nor FDCPA defines “obligation.” Applying its ordinary meaning, the term includes a debt.

4. “Value” and “Reasonably Equivalent Value” Defined HUFTA and FDCPA provide that “value is given for a transfer or an

obligation if in exchange for the transfer or obligation property is 6 transferred or an antecedent debt is secured or satisfied . . .” Haw. Rev.

Stat. § 651C-3; 28 U.S.C. § 3303(a). HUFTA and FDCPA do not provide a general definition of

“reasonably equivalent” value. Haw. Rev. Stat. §651C-3(b) and 28 U.S.C.

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