A North Carolina appeals court just shut down Greg Lindberg's attempt to shield assets from an insurer by parking them in an out-of-state LLC.
On May 20, 2026, the North Carolina Court of Appeals affirmed that Universal Life Insurance Company can collect on its judgment against Lindberg by reaching his economic interest in Global Growth Holdings, LLC, a Delaware-organized entity. The ruling is a useful precedent for any insurer chasing a debtor who has shifted assets across state lines.
Here's the setup. After winning an earlier judgment against Lindberg, the insurer asked a Durham County court in April 2024 for a charging order – a court-ordered claim on any distributions Lindberg would otherwise collect from Global. The complication: Global had been organized as a Delaware corporation, and in December 2023 Lindberg converted it into a limited liability company.
Lindberg argued the trial court couldn't touch it. His position was that North Carolina's Limited Liability Company Act only reaches LLCs formed in the state, and that the court lacked authority over property sitting out of state.
Judge Michael J. O'Foghludha granted the charging order anyway, in July 2024. Lindberg appealed.
The appeals court walked through the statute and shut both arguments down. On the out-of-state question, the court read the text plainly. The Act defines a limited liability company as either an LLC or a foreign LLC, and a foreign LLC includes entities organized under another state's law and called a limited liability company there. That covers Delaware. Writing for the panel, Judge Carpenter said that once a court has personal jurisdiction over the owner of the interest, a judgment creditor can charge that owner's economic interest in both foreign and North Carolina LLCs.
The court also brushed aside Lindberg's argument that the statutory definition of distribution pinned the law to in-state LLCs. The definition has two alternative parts, and one of them – transfers from an LLC for the benefit of an interest owner – doesn't draw any in-state line.
On jurisdiction, the panel said the trial court didn't need power over Global itself. A charging order, the opinion explained, works as a lien on the debtor's economic interest. It reaches the debtor's personal property, not the LLC's. Personal jurisdiction over the debtor is enough.
And the court had that. By contesting jurisdiction over the property in his response without challenging jurisdiction over himself, Lindberg made what the panel called a general appearance – which, under North Carolina law, is grounds for personal jurisdiction on its own.
Judges Stroud and Wood concurred.
For insurers, the lesson is direct. A debtor's mid-fight conversion of a corporation into an out-of-state LLC isn't a hiding place. North Carolina courts can still reach the debtor's economic interest in that entity, and creditors don't need to drag the foreign LLC itself into court to do it.
