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Bo Fontana v. Tiffany & Co.

2026-08-27

Summary

Holding. The court reversed the receivership order in part and affirmed in part. The order is valid and enforceable only as to the Eight Assets (the Tiffany jewelry, four identified real properties, and three photographed vehicles), but invalid as to all other non-exempt assets owned by Fontana for which Tiffany presented insufficient evidence of ownership.

Fontana purchased jewelry from Tiffany & Co. on credit and failed to pay. After obtaining a judgment for over $985,000, Tiffany sought a post-judgment receivership to recover unpaid amounts. The trial court appointed a receiver over all of Fontana's non-exempt assets without limiting the order to specific identified property. On appeal, Fontana argued the receivership order was overly broad because Tiffany failed to present sufficient evidence of his ownership of most assets covered by the order.

The court of appeals held that while a trial court may issue a turnover order covering assets without specifically identifying each one, this discretion has limits. When a trial court appoints a receiver, there must be at least some substantive and probative evidence presented at the hearing establishing that the judgment debtor owns each asset subject to the receivership. The court found adequate evidence for eight specific assets: the Tiffany jewelry at issue, four parcels of real property, and three vehicles (a boat, trailer, and travel trailer). However, the broader language in the original order—covering all non-exempt assets owned by Fontana—exceeded what the evidence supported and therefore constituted an abuse of discretion.

Fontana also raised a second issue regarding the absence of a mechanism in the order to pay for family necessities, but the court declined to address it because he failed to properly preserve this complaint for appeal.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether a post-judgment receivership order is final and appealable despite not being a traditional final judgment
  • Whether a trial court abuses its discretion by appointing a receiver over assets lacking evidentiary support
  • Whether each asset subject to a turnover order requires proof of the debtor's ownership

Procedural posture

Fontana appeals from a trial court order appointing a post-judgment receiver over his property to satisfy a judgment debt owed to Tiffany & Co.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

Court of Appeals

Tenth Appellate District of Texas

10-24-00346-CV

Bo Fontana,

Appellant

v.

Tiffany & Co.,

Appellee

On appeal from the

18th District Court of Johnson County, Texas

Judge Sydney B. Hewlett, presiding

Trial Court Cause No. DC-C202300102

JUSTICE HARRIS delivered the opinion of the Court.

MEMORANDUM OPINION

Appellant, Bo Fontana (hereafter “Fontana”), appeals from a turnover

order rendered by the trial court in proceedings initiated by Appellee, Tiffany

& Co. (hereafter “Tiffany”), to recover certain pieces of jewelry purchased on

credit by Fontana and left unpaid. In two issues, Fontana asserts that the trial

court abused its discretion by appointing a post-judgment receiver over

property for which Tiffany produced insufficient evidence that Fontana owned,

and that the trial court’s order did not provide a mechanism to allow Fontana to provide necessities for his family. Tiffany asserts that we lack jurisdiction

over this appeal because the order is not a final, appealable order. We will first

address whether this turnover order is final and appealable as to convey

appellate jurisdiction. We find that the order is final for purposes of appeal,

and we reverse the receivership order, in part, and render the order invalid as

to “all non-exempt assets owned, directly or indirectly, by Bo Fontana,” and

valid as to only the “Eight Assets” set forth below.

Background

On February 10, 2023, Tiffany filed suit against Fontana in the 18th

Judicial District Court of Johnson County, Texas, to recover amounts owed for

certain pieces of jewelry purchased by Fontana. On January 31, 2024, the

parties entered a Rule 11 Settlement Agreement in which Fontana agreed to

pay Tiffany $687,500.00 on or before March 1, 2024. Fontana did not pay the

sum by that date. The trial court subsequently entered an agreed judgment

awarding Tiffany recovery in the amount of $985,492.50. Fontana did not pay

this judgment either.

Tiffany later filed a motion for a post-judgment receivership. Fontana

filed a response. On October 3, 2024, the court held a hearing on the motion,

during which the trial court informed the parties it would be granting the

motion. The trial court gave the parties an opportunity to strike and revise

provisions in an Order Appointing Receiver and Compelling Discovery. The Fontana v. Tiffany & Co. Page 2 parties made revisions. Beyond those revisions and a comment by counsel for

Fontana that he is “opposed to the receiver,” the parties did not object to any

provisions in the order. On the same day, the trial court granted the motion

and entered the Order Appointing Receiver and Compelling Discovery which

is the subject of this appeal. Fontana filed his notice of appeal on October 22,

2024.

Turnover Order

The “Turnover Statute” provides judgment creditors with a procedural

device to assist them in satisfying their judgment debts. Beaumont Bank, N.A.

v. Buller, 806 S.W.2d 223, 224 (Tex. 1991). To accomplish turnover, a court

may “appoint a receiver with the authority to take possession of the nonexempt

property, sell it, and pay the proceeds to the judgment creditor to the extent

required to satisfy the judgment.” TEX. CIV. PRAC. & REM. CODE § 31.002(b)(3).

I. Jurisdiction

Usually, only final judgments are subject to appeal. Alexander Dubose

Jefferson & Townsend LLP v. Chevron Phillips Chem. Co., L.P., 540 S.W.3d

577, 582 (Tex. 2018). However, the finality of turnover orders differs from the

traditional concept of finality. Id. A turnover order is final and appealable if it

was in the nature of a mandatory injunction. Schultz v. Fifth Jud. Dist. Ct. of

Appeals at Dall., 810 S.W.2d 738, 740 (Tex. 1991), abrogated on other grounds,

In re Sheshtawy, 154 S.W.3d 114 (Tex. 2004). A provision of a turnover order Fontana v. Tiffany & Co. Page 3 is in the nature of a mandatory injunction if it requires a party to take

affirmative action. See Alexander Dubose Jefferson & Townsend LLP, 540

S.W.3d at 587 (stating that a portion of a turnover order was in the nature of

a mandatory injunction because it required the judgment debtor to deliver

funds directly to the judgment creditor).

Through multiple provisions, the order directed Fontana to deliver to the

receiver “all non-exempt assets owned, directly or indirectly, wherever located,

including accounts, personal property, intangible property, and real property.”

These provisions order Fontana to take affirmative action and are thus

injunctive and appealable. See Alexander Dubose Jefferson & Townsend LLP,

540 S.W.3d at 587; see also Schultz, 810 S.W.2d at 740. Having determined

that these provisions are final for purposes of appeal, we turn to the breadth

of these provisions.

II. Evidence Supporting Turnover Order

By his first issue on appeal, Fontana asserts that the trial court abused

its discretion in appointing a post-judgment receiver over property for which

Tiffany produced insufficient evidence that Fontana owned. Fontana

essentially argues that the turnover order is too broad.

Standard of Review

We review a trial court's order requiring turnover and appointing a

receiver under an abuse of discretion standard. Beaumont Bank, N.A. v. Buller, Fontana v. Tiffany & Co. Page 4 806 S.W.2d 223, 226 (Tex. 1991). A trial court may be reversed for abusing its

discretion only when it acts in an unreasonable or arbitrary manner, that is, if

it acts without reference to any guiding rules and principles. Id. A trial court's

issuance of a turnover order will not be reversed for abuse of discretion if the

judgment is sustainable for any reason. Id. Whether there was no evidence to

support the turnover award is a relevant consideration in determining if the

trial court abused its discretionary authority in issuing the order. Id.

Applicable Law

Section 31.002(a) states that “a judgment creditor is entitled to aid from

a court of appropriate jurisdiction, including a justice court, through injunction

or other means in order to reach property to obtain satisfaction on the

judgment if the judgment debtor owns property, including present or future

rights to property, that is not exempt from attachment, execution, or seizure

for the satisfaction of liabilities.” TEX. CIV. PRAC. & REM. CODE § 31.002(a). The

statute does not specify or restrict the way in which evidence may be received

for a trial court to determine whether Section 31.002(a) is satisfied. Klinek v.

LuxeYard, Inc., 672 S.W.3d 830, 835 (Tex. App.—Houston [14th Dist.] 2023, no

pet.). The statute does not require that such evidence be in any particular

form, reach any particular level of specificity, or reach a particular quantum

before the court may grant aid under Section 31.002. Id. The statute only

requires that the judgment debtor: (1) own property (including present or Fontana v. Tiffany & Co. Page 5 future rights to property) and (2) that is not exempt from attachment,

execution, or seizure for the satisfaction of liabilities. TEX. CIV. PRAC. & REM.

CODE § 31.002(a).

Discussion

At the hearing on the Motion for Post-Judgment Receivership, Tiffany

submitted evidence in an attempt to prove Fontana owned various property.

Fontana admits that Tiffany proved Fontana had an ownership interest in

three assets: (1) jewelry Fontana purchased from Tiffany, which is the subject

of the underlying judgment, (2) real property located at 105 Syble Jean Drive,

and (3) real property located at 401 Madeline Lane. Fontana argues that

Tiffany did not prove the ownership of any assets other than the Three Assets.

We do not think that Tiffany must definitively prove the ownership of every

asset the order covers. Instead, we hold that as long as some evidence of a

substantive and probative character tending to prove that Fontana owned a

particular asset was before the trial court when it signed the order, then the

trial court did not abuse its discretion as to that asset. See Tanner v. McCarthy,

274 S.W.3d 311, 331 (Tex. App.—Houston [1st Dist.] 2008, no pet.) (“A trial

court will not be reversed for an abuse of discretion so long as there is some

evidence of a substantive and probative character to support the decision.”).

Moreover, while Section 31.002(h) provides that “a court may enter or

enforce an order under this section that requires the turnover of nonexempt Fontana v. Tiffany & Co. Page 6 property without identifying in the order the specific property subject to

turnover,” several Texas courts require evidence for each asset subject to the

order. TEX. CIV. PRAC. & REM. CODE § 31.002(h); See Hamilton Metals, Inc. v.

Glob. Metal Servs., Ltd., 597 S.W.3d 870, 883 (Tex. App.—Houston [14th Dist.]

2019, pet. denied) (holding that a trial court abused its discretion in signing a

receivership order to the extent the order applied to property other than that

which was sufficiently evidenced before the court); see also Great N. Energy,

Inc. v. Circle Ridge Prod., Inc., No. 06-16-00029-CV, 2016 WL 7912458, at *11

(Tex. App.—Texarkana Sept. 28, 2016, no pet.) (same); Stanley v. Reef Sec.,

Inc., 314 S.W.3d 659, 669 (Tex. App.—Dallas 2010, no pet.) (same). We join

the Houston, Dallas, and Texarkana courts and hold that for a trial court to

issue a turnover order, each piece of property to be subject to the order must

be sufficiently evidenced before the trial court.

The evidence before the trial court when it signed the turnover order was

legally sufficient to show that Fontana had ownership interests in the following

property or assets:

1) certain pieces of jewelry Fontana purchased from Tiffany which are

the subject of the underlying judgment;

2) real property located at 105 Syble Jean Drive;

3) real property located at 401 Madeline Lane;

4) real property located at 1400 East Tioga Court;

Fontana v. Tiffany & Co. Page 7

5) real property located at 330 Madeline Lane;

6) the photographed boat depicted in the record;

7) the photographed trailer depicted in the record;

8) the photographed travel trailer depicted in the record

(collectively, the “Eight Assets”). It is undisputed that Tiffany proved the

ownership of the first three assets. As for the remaining five assets, the record

shows that there was some evidence of a substantive and probative character

tending to prove Fontana owns these assets before the trial court when it

issued the order. Fontana admitted to owning real property located at 1400

East Tioga Court and real property located at 330 Madeline Lane in a

deposition from another lawsuit. The boat, trailer, and travel trailer can be

seen on Fontana’s property in photographs. Fontana’s interests in any

corporation, limited liability company, general partnership, and limited

partnership were clearly excluded from the order during the parties’ revisions.

Accordingly, the assets held by any such entities, in which Fontana has an

ownership interest, are not subject to the turnover order and are not included

in this discussion.

As for the Eight Assets, we hold that there was at least some substantive

and probative evidence that Fontana owned those assets in front of the trial

court when it signed the order. See Tanner, 274 S.W.3d at 331. To the extent

that the trial court appointed a receiver over “non-exempt assets owned, Fontana v. Tiffany & Co. Page 8 directly or indirectly, by Bo Fontana,” other than the Eight Assets, the order

was not sufficiently supported by evidence and constituted an abuse of

discretion. See Hamilton Metals, Inc., 597 S.W.3d at 883; see also Great N.

Energy, Inc., 2016 WL 7912458 at *11; Stanley, 314 S.W.3d at 669.

Fontana’s first issue is sustained in part as to “all non-exempt assets

owned, directly, or indirectly, by Bo Fontana,” other than the Eight Assets.

III. Necessities

Additionally, Fontana complains that the order does not provide any

mechanism for Fontana to pay for necessities. Fontana does not argue that

this constitutes an abuse of the trial court’s discretion, but rather requests this

Court provide such a mechanism. While Fontana complained at the hearing

about a lack of such a provision, Fontana did not object to said missing

provision. Moreover, Fontana was afforded the opportunity to revise the order

prior to its signing but did not add such a provision. Consequently, Fontana

did not preserve this complaint for appeal. TEX. R. APP. P. 33.1; D & M Marine,

Inc. v. Turner, 409 S.W.3d 853 (Tex. App.—Fort Worth 2013, no pet.) (declining

to reverse a turnover order for error not properly preserved for appeal).

Fontana’s second issue is overruled.

Conclusion

The trial court did not abuse its discretion in appointing a receiver as to

the Eight Assets. As for “all non-exempt assets owned, directly or indirectly, Fontana v. Tiffany & Co. Page 9 by Bo Fontana,” subject to the order other than the Eight Assets, the trial court

abused its discretion in appointing a receiver over them. Accordingly, we

reverse the receivership order in part and render the order invalid as to “all

non-exempt assets owned, directly or indirectly, by Bo Fontana,” and valid as

to only the Eight Assets.

LEE HARRIS

Justice

OPINION DELIVERED and FILED: August 27, 2026

Before Chief Justice Johnson,

Justice Smith, and

Justice Harris

Reversed and rendered in part

Affirmed in part

CV06

Fontana v. Tiffany & Co. Page 10