The North Carolina Court of Appeals recently upheld a ruling that allows Universal Life Insurance Company (ULICO) to place a charging order on Greg E. Lindberg's economic interest in Global Growth Holdings, LLC. This decision, made on May 20, 2026, affects Lindberg's ability to manage his financial interests following a judgment against him. The ruling clarifies the application of charging orders to foreign limited liability companies (LLCs) and asserts the court's jurisdiction over Lindberg's assets.

In the case, which is recorded under docket number 25-6, ULICO sought to collect on a judgment by filing a motion for a charging order against Lindberg's economic interest in Global. Lindberg contested the motion, arguing that the North Carolina Limited Liability Company Act does not allow charging orders against foreign LLCs and that the trial court lacked jurisdiction over his out-of-state assets. However, the court ruled in favor of ULICO, stating that the Act does permit such orders.

This case stems from a broader legal dispute involving Lindberg, who has faced multiple legal challenges regarding his business dealings and financial obligations. The initial judgment against him prompted ULICO to pursue a charging order to secure its interests in Lindberg's assets. The case highlights the complexities of asset recovery in situations involving foreign LLCs and the jurisdictional challenges that can arise.

ULICO filed its motion for a charging order on April 17, 2024, following a previous judgment against Lindberg. The trial court granted the motion on July 16, 2024, after a hearing in which Lindberg presented several arguments against the order. He contended that ULICO had not executed a writ of execution and that there was an ongoing appeal of prior orders. Additionally, he claimed that the court could not charge his property located outside North Carolina.

The trial court found that Lindberg owned all outstanding membership rights in Global due to his ownership of stock in Global Growth Holdings, Inc. before its conversion to an LLC. The court concluded that it had personal jurisdiction over Lindberg and that it could issue the charging order despite Global being a foreign entity.

The Court of Appeals, led by Judge Jeff Carpenter, affirmed the trial court's decision, stating, "The Act contemplates issuance of a charging order to foreign and domestic LLCs, and the trial court had statutory authority to issue the Charging Order after establishing personal jurisdiction over the interest owner." The court clarified that charging orders are not directed at foreign LLCs but rather concern the personal property of the judgment-debtor.

One key aspect of this ruling is its affirmation of the court's ability to exercise personal jurisdiction over defendants, even when their assets are held in foreign entities. The court explained that if personal jurisdiction exists over the interest owner, the trial court can issue a charging order without needing in rem or quasi in rem jurisdiction over the foreign LLC itself.

This ruling is significant for judgment creditors seeking to collect debts from individuals with economic interests in foreign LLCs. It establishes that North Carolina courts can enforce charging orders on economic interests in foreign entities, provided they have personal jurisdiction over the debtor. This could set a precedent for future cases involving similar circumstances, potentially expanding the reach of creditors in collecting judgments against debtors with complex asset structures.

The outcome of this case may have broader implications for how courts in North Carolina handle charging orders and jurisdictional issues involving foreign LLCs. Creditors may find it easier to secure their interests in cases where debtors hold assets in entities not formed under North Carolina law. This decision thus reinforces the authority of North Carolina courts in matters of judgment collection and asset recovery.

Looking ahead, it is unclear whether Lindberg will seek further appeals following this ruling. The court’s decision is final unless a higher court, such as the North Carolina Supreme Court, chooses to review the case. As it stands, the ruling indicates a clear path for creditors to pursue charging orders against judgment debtors with economic interests in foreign entities.