Reverse Alter Ego

Below are cases involving reverse alter ego, or cases where a creditor invades the assets of a corporation based on the debts of its owner. Note that the modern trend is for courts to consider "reverse alter ego" and traditional "alter ego" to be no different. But note that while all states recognize alter ego theories, some states have rejected the reverse alter ego theory.

Michael L. Daymon and Kathryn Daymon v. Ted L. Fuhrman,
No. 249007 (Mich.App. 10/05/2004)

Neibaur v. Neibaur,
No. 29871 (Idaho App. 07/30/2004)

Sweeney, Cohn, Stahl & Vaccaro v. Kane,
2004.NY.0001802 (N.Y.App.Div. 03/08/2004)

Baum Hydraulics Corporation v. United States,
4:01 CV454 (Neb.Dist. 09/08/2003)

C.F. Trust, Inc. v. First Flight Limited Partnership,
580 S.E.2d 806 (Va. 06/06/2003)

Nutrition Rich Products, Inc. v. Nutritional Resources, Inc.,
2003.KY.0000201 (Ky.Commw. 02/21/2003)

Litchfield Asset Management Corp. v. Howell,
799 A.2d 298 (Conn.App. 06/04/2002)

Nippon Credit Bank, Ltd. v. Matthews,
291 F.3d 738 (11th Cir. 05/15/2002)

Pierce v. State,
564 S.E.2d 790 (Ga.App. 04/30/2002)

Great Neck Plaza, L.P. v. Le Peep Restaurants, LLC,
37 P.3d 485 (Colo.App. 08/16/2001)

Humitsch v. Collier,
2000.OH.0047938 (Ohio App. Dist.11 12/29/2000)

LFC Marketing Group, Inc. v. Loomis,
116 Nev. 896; 8 P.3d 841 (09/19/2000)

Manufacturers Consolidation Service, Inc. v. Rodell,
2000.TN.0042702 (Tenn.App. 03/10/2000)

Clark v. United Technologies Automotive,
594 N.W.2d 447 (Mich. 06/02/1999)

Dipchan Kissondath v. Safeco Insurance,
No. 958992 (Minn.App. 11/19/1996)

Estate of Sammy G. Daily v. Lilipuna Associates,
81 F.3d 167 (9th Cir. 04/04/1996)

Douglas W. Olen v. Frank K. Phelps,
1996.WI.533 (WI.App. 02/08/1996)

Osborne Properties v. Bruce Edward,
1995 MN 21165 (Minn.App. 08/15/1995)

Additional Resources

• Good Lessons from Bad Cases
  Jay Adkisson's presentation to the Florida Bar Association's Asset Protection seminar, March 13, 2006, explores charging orders, reverse alter ego, and attorney liability issues.

Reverse Alter Ego Terms

• Reverse Alter Ego
  A developing theory of relief for creditors, which allows creditors of an owner of an entity to invade the entity and get at the entity's assets directly so as to satisfy the creditor's debt against the owner.

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