Not a transfer, so not a fraudulent transfer.

The Fullers won a judgment against the Balthazars for a fraudulent transfer, arising from an earlier state court proceeding. The Fifth Court eliminated two elements of their judgment. First, it limited their recovery to “the value of the assets the Fullers proved were fraudulently transferred,” rather than the entire amount of the previous state-court judgment. Second, it did not allow recovery for a discovery sanction levied in the original case, as the Balthazars were not parties to it, and the sanction did not come within the statutory measure of “the value of the asset transferred . . . or the amount necessary to satisfy the creditor’s claim, whichever is less.” Balthazar & Sons v. Fuller, No. 05-17-00956-CV (June 25, 2018) (mem. op.)