ESQ HQNEW YORK LAW WATCH

Appellate Division, First Department · September 24, 2026 · 2026 NY Slip Op 05460

The “transaction attacked” in veil-piercing can be the transfer that emptied the till

Matter of UBS Sec. LLC v Dondero

Read the official decision: 2026 NY Slip Op 05460

Holding The court held that the ‘transaction attacked’ in a veil-piercing claim can be a subsequent asset transfer designed to frustrate judgment recovery, not just the original underlying transaction. While the alter ego claim against Dondero survived for the corporate entities, it was dismissed regarding limited partnerships and against Ellington for lack of sufficient allegations of complete domination.

Why it matters

Clarifies the scope of the ‘transaction attacked’ element in New York veil-piercing cases, allowing claims based on post-judgment asset dissipation.

Addresses the applicability of veil-piercing doctrines to limited partnerships, distinguishing them from corporations for pleading purposes.

The court’s words

the 'transaction attacked' need not be the underlying transaction itself, but can be a subsequent transaction designed to frustrate a party's ability to recover

2026 NY Slip Op 05460, at the official text

That Ellington was an influential corporate officer who served as the right-hand of the individual who allegedly dominated the corporate entities does not expose Ellington to alter ego liability

2026 NY Slip Op 05460, at the official text

New York law controls because UBS Securities LLC, one of the judgment creditors that claims to have been defrauded, is headquartered and has its principal place of business in New York

2026 NY Slip Op 05460, at the official text
CourtAppellate Division, First Department
DecidedSeptember 24, 2026
Citation2026 NY Slip Op 05460
Area of lawCorporate, Securities and Business · Civil Procedure
WeekWeek ending September 26, 2026
Official textOfficial decision: 2026 NY Slip Op 05460
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id121

Same court and area in the last 180 days

Recommended citation

ESQ HQ, New York Law Watch, Matter of UBS Sec. LLC v Dondero, 2026 NY Slip Op 05460 (Appellate Division, First Department, September 24, 2026), https://esqhq.com/decisions/2026-ny-slip-op-05460/

How this record was made

Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.

Read how Law Watch works

Featured by Eric McAvey, November 14, 2026.

Published September 24, 2026. Updated November 14, 2026.