Definition
Latin: "no goods." A formal return made by a sheriff to a writ of execution when the officer has searched within the jurisdiction and found no goods, chattels, or other leviable property belonging to the judgment debtor. The return operates as an official certification of the fruitless levy attempt, and is sometimes abbreviated or recorded simply as "nulla bona."
The return is procedurally significant: it documents that the creditor has exhausted the most direct avenue of collection and typically opens the door to alternative enforcement remedies — including body execution (in jurisdictions and eras that permitted it), supplementary proceedings, creditor's bills in equity, or examination of the debtor's assets before a court.
Why It Matters in Research
The nulla bona return is a pivot point in the enforcement sequence, and researchers who miss it may misread the procedural posture of a case. In historical records — court files, docket books, sheriff's returns — the phrase often appears in abbreviated or anglicized form ("no goods," "n.b.," or simply a notation in the return column). Researchers scanning older court papers should recognize these shorthand variants as legally operative returns, not mere informal notes.
Temporal context matters significantly. In many American jurisdictions through the nineteenth century, a nulla bona return was one of the prerequisites that allowed a creditor to pursue body execution — arrest and imprisonment of the debtor. As debtor's prison reform swept through the states (accelerating from the 1830s onward), the procedural consequences of a nulla bona return shifted away from personal imprisonment toward supplementary discovery and creditor's remedies in equity. Tracing those changes is essential when researching collection litigation in historical court records.
The return also intersects with fraudulent conveyance doctrine. A nulla bona return frequently appears as the initiating fact in cases where creditors alleged that a debtor had transferred property to defeat collection. The return established that no property was findable at the time of levy — which creditors then used to support claims that assets had been fraudulently conveyed before the writ issued. Researchers following that litigation trail should move from the nulla bona return to any subsequent equity proceedings or fraudulent conveyance actions in the same court file or term dockets.
Jurisdictional variation in how sheriffs framed returns, and what procedural steps were required after a nulla bona, means that researchers should not assume uniform practice even within a single historical era. Local court rules, statutes governing executions, and equity practice all shaped what happened next.
Historical Dictionary Support
Black's Law Dictionary defines nulla bona as "no goods" and identifies it squarely as the sheriff's return when no leviable property of the defendant has been found within the officer's jurisdiction. This is consistent and uncontroverted across the historical legal dictionary tradition — the term carries a single, technically precise meaning that has not meaningfully shifted over time.
Black's also appends a passage from Coke (8 Coke, 60) on a related maxim: "Nulla curia quae recordum non habet potest imponere finem neque aliquem mandare carceri" — no court lacking a record can impose a fine or commit anyone to prison. This maxim appears in Black's alongside the nulla bona entry and relates to the broader Latin "nulla" family of legal terms rather than to the return itself. Researchers should note the connection is associative, not substantive; the Coke maxim governs court jurisdiction, not execution practice.
Historical dictionaries are largely silent on the downstream procedural significance of the return — what it triggered, how it was recorded in practice, and how its consequences changed with debtor-creditor reform. For that dimension, researchers must look beyond dictionary sources to treatises on execution practice and contemporary equity procedure.
Jurisdictional Note
The nulla bona return was standard practice across common law jurisdictions in England and the American states, but the consequences of the return varied by jurisdiction and period. Some states by statute required a nulla bona return as a formal prerequisite before supplementary proceedings could be initiated; others were less rigid. Researchers working with specific state court records should consult the applicable execution statutes in force at the time of the proceedings.