Pearce v. Stone
In Pearce v. Stone, 149 Ariz. 567, 720 P.2d 542 (App. 1986) the Court stated that the lawsuit for conspiracy to commit a fraudulent conveyance had been filed pursuant to the criminal statute prohibiting fraudulent schemes and artifices, the racketeering statutes, and "the common law of fraudulent conveyance." 149 Ariz. at 569, 720 P.2d at 544.
In reciting the facts, however, the court stated the plaintiff had alleged that the defendant had made fraudulent conveyances in violation of UFCA.
In a subsequent footnote, the court pointed out that, despite the plaintiff's mention of a common law action for fraudulent conveyance, he had argued only that the defendant had violated UFCA.
Accordingly, the court limited its discussion to the elements of a fraudulent conveyance under UFCA and did not address the issue of whether a common law cause of action remained after UFCA was adopted.