Definition
No goods is the English-language equivalent of the Latin return *nulla bona*. It is the formal written return made by a sheriff or constable upon a writ of execution when, after diligent search, the officer has found no property belonging to the judgment debtor on which to levy. The return communicates to the issuing court that the writ cannot be satisfied because no leviable assets were located within the officer's jurisdiction.
The return is not a finding of insolvency, nor a final judgment on the debtor's financial condition. It is a procedural report — the officer's official account of what occurred when enforcement was attempted.
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Common Confusion
No goods is sometimes loosely conflated with a finding that the debtor *has* no assets. The return means only that no assets were found in the search conducted. The debtor may hold property elsewhere, may have concealed or transferred assets, or may possess property of a type not subject to execution under applicable exemption law. Researchers should treat a *nulla bona* return as a starting point for further inquiry — into fraudulent conveyance, exemption claims, or multi-jurisdictional asset searches — not as a conclusion about actual solvency.
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Why It Matters in Research
**Procedural trigger.** A *nulla bona* return historically unlocked additional creditor remedies. In equity practice, it was frequently a prerequisite to a creditor's bill — the equitable proceeding used to reach assets a court of law could not touch. Researchers tracing pre-merger equity practice (before the Federal Rules unified law and equity in 1938) will encounter this return as a threshold requirement in chancery records and equity treatises.
**Archival terminology.** In historical court records, execution returns appear as brief notations on the writ itself or in the execution docket. The Latin *nulla bona* and the English *no goods* appear interchangeably across different periods and jurisdictions. When indexing or searching historical dockets, researchers should query both forms.
**Exemption law intersection.** What counts as "goods" subject to levy varied considerably by jurisdiction and era. Homestead exemptions, tools-of-trade exemptions, and personal property exemptions meant an officer might return *no goods* even where a debtor held visible property — because that property was shielded. The return alone does not reveal whether assets were absent or exempt; the distinction matters greatly in historical insolvency research.
**Fraudulent conveyance investigations.** A *nulla bona* return appearing in historical records may signal a fraudulent transfer investigation. When creditors received this return, the next step was often a bill in equity to set aside conveyances made to hinder collection. Researchers examining 19th-century equity records should look for creditor's bills filed shortly after *nulla bona* returns in the execution docket.
**Modern practice.** Contemporary enforcement proceedings use similar concepts under state civil procedure rules governing execution, but the formal *nulla bona* / *no goods* return language has been largely replaced by statutory forms and updated procedural terminology. Historical sources use the term with more technical precision than modern materials.
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Historical Dictionary Support
Both editions of Black's Law Dictionary define *no goods* identically: it is the English equivalent of *nulla bona*, being the form of the return made by a sheriff or constable charged with an execution when he has found no property of the debtor on which to levy. The two editions are in full agreement on substance, reflecting that the term's technical meaning was stable and uncontested.
Notably, both editions embed the *no goods* entry within a run of maxims and related entries, which reflects the structure of early legal dictionaries rather than any conceptual connection between *no goods* and the surrounding maxims. Researchers consulting facsimile or digitized versions of early Black's should not infer a doctrinal relationship from proximity on the page.
What the historical dictionaries do not address: the procedural consequences of the return (the creditor's bill remedy, the effect on limitations periods, the options available to the judgment creditor after receiving the return). Those details must be sought in equity treatises, civil procedure commentaries, and jurisdiction-specific practice guides from the relevant period.
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Jurisdictional Note
The *nulla bona* return existed in every American jurisdiction that inherited English common law execution practice, but the specific procedures following the return — and the range of property subject to levy — varied significantly by state statute. Exemption laws in particular differed widely, meaning that a *no goods* return in one state might reflect entirely different factual and legal circumstances than the same return in another.
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