Target Corp. v. Amerson, 326 Ga. App. 734

Plaintiffs Greens and Target contested a jury verdict finding fraudulent transfer to defeat Amerson’s judgment.
Amerson obtained a money judgment against the Greens on February 5, 2009; liens were filed March 26, 2009.
Target, via Plus Relocation, arranged appraisals and a “clear title” search to facilitate Greens’ relocation.
Target purchased the Property on May 4, 2009 without knowledge of Amerson’s lien; Greens paid remaining construction loan balance at closing.
Greens moved to North Carolina; Target’s purchase left Greens without possession but with control relinquished to a third-party title company pending sale.
The trial court denied directed verdict motions; the jury found fraudulent transfer and bad faith; no ruling on the judgment lien was made.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is legally sufficient evidence of fraud to submit to the jury	Amerson argues multiple badges of fraud support intent to defraud	Greens and Target contend evidence fails to show actual intent	No; insufficient evidence to sustain fraudulent-transfer verdict
Whether the judgment lien was properly filed during pendency of motions	Amerson asserts lien validity affects priority	Greens/Target argue lien timing improper	Not reached; trial court’s lien ruling deemed unnecessary to address on appeal

BFP v. Resolution Trust Corp., 511 U.S. 531 (1994) (modern fraudulent-transfer doctrine; badges of fraud concept adopted)
Sun Nurseries, Inc. v. Lake Erma, LLC, 316 Ga. App. 832 (2012) (badges of fraud; no single factor controls)
Merrell v. Beckwith, 263 Ga. 779 (1994) (conveyances between relatives; close scrutiny; jury question)
Moore v. Moore, 281 Ga. 81 (2006) (circumstantial evidence must support a verdict on fraud)
Powell v. Westmoreland, 60 Ga. 572 (1878) (question of fraud in deeds judged by circumstances)
Allen Kane’s Major Dodge, Inc. v. Barnes, 243 Ga. 776 (1979) (exemplary discussion of circumstantial evidence and fraud)