Crider v. Crider (2014)
Decided August 26, 2014. The complete published opinion was retrieved from the unofficial Justia primary-opinion mirror in overlapping windows covering the entire opinion on 2026-10-17. The relevant forced-transfer holding is Part VII, opinion pages 40–49; the other valuation, support and enforcement rulings are not recast as sale rules.
Source note (2026-10-18):
- source replaced 2026-10-18: static.case.law robots-disallowed; official copy at Indiana Judicial Branch official appellate decisions (No. 53A05-1307-DR-358) (replaces
https://static.case.law/ne3d/15/cases/1042-01.json; retrieval dates stated elsewhere on this page refer to the earlier copy).
Facts
A dissolution judgment required Jeffrey Crider to make an equalization payment of roughly USD 4.7 million to Christina. It secured payment with interests in closely held family businesses and purported to transfer ownership/control of half his stock and LLC interests automatically if he did not pay within 180 days. The entities had not originally been joined and later intervened. Source: complete opinion, facts and Part VII.
Holding
The court upheld the ability to secure the equalization obligation, but reversed the automatic transfer of ownership and control. For corporate stock, it permitted a limited equitable interest in specified nonvoting-share distributions or a sheriff’s sale under IC 34-55-3-5 with notice to the corporation and the applicable corporation/shareholder rights of first refusal. A purchaser with notice of transfer restrictions would be bound by their future application. The restrictions did not absolutely immunize stock from execution to satisfy the dissolution judgment. Source: Part VII, pages 41–47.
For LLC interests, following brant-v-krilich-in-2005, the trial court could issue charging orders after proceedings in which the LLCs could participate. The creditor would receive distributions, without management or membership rights. Distributions must be credited against the debt; the charging orders terminate when the judgment is satisfied. Source: Part VII, pages 47–49.
Reasoning and boundaries
The court distinguished stock from LLC interests and economic benefits from control. It declined the unsupported argument that Article 9 necessarily governed a court-imposed judgment lien (footnote 13). The decision does not authorize taking an LLC’s underlying equipment or accounts merely because its member owes the judgment. It concerned multiple members and supplies no adjudicated single-member management-transfer exception. Source: Part VII, pages 44–49.
Good-law status
The holding is verified from the complete opinion. Comprehensive subsequent appellate
history and later negative treatment remain needs_verification; no automatic still-good
certification is inferred from retrieval. This supplementary treatment question does not
make the opinion an unverified or invented case.
Full-text recheck (2026-10-18). The complete opinion (Barnes, J.) was re-read in the verbatim Indiana Judicial Branch official opinion PDF (unofficial archive) after law.justia.com returned HTTP 403. Part VII holds that the trial court exceeded statutory authority by giving the ex-wife control of LLC membership interests; she must seek a charging order with notice to the LLCs, and corporate stock may be reached by sheriff’s sale under IC 34-55-3-5 subject to the stock-transfer agreement’s first-refusal rights.
Applies in →
indiana · equity-interests-stock-llc-charging-orders
Legal information, not legal advice. Read the full opinion, current entity statutes and operative order.