Allen v. Helvering

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that “an action to collect a judgment . . . does not require an independent jurisdictional basis and may proceed even if the parties are non-diverse.”
• holding that a claim by a judgment creditor against a judgment debtor and third parties to whom debtor had fraudulently conveyed liens could proceed under the ancillary jurisdiction of the district court
• concluding that the district court had ancillary enforcement jurisdiction where one party only attempted to void the allegedly fraudulent conveyances of defendant to and among other defendant parties, in order to ensure the plaintiff’s collectability of the default judgment
• noting that the “important distinction is not whether the claim is brought in a second action but whether it seeks to impose liability for the underlying judgment on a new party.”
• “[V]eil-piercing claims in a subsequent action require an independent jurisdictional basis.”
• distinguishing post-judgment proceedings to void a fraudulent conveyance and collect an existing judgment from claims asserted under an alter ego or veil piercing theory “that raise an independent controversy with a new party in an effort to shift liability”

Source: CourtListener parenthetical corpus (CC0).