Do Texas courts have to assign dollar values to non-cash assets like airline miles in garnishment cases?

Q: Do Texas courts have to assign dollar values to non-cash assets like airline miles in garnishment cases?

Vodicka v. Tobolowsky: When enforcing a judgment or dividing property involving intangible assets like airline miles or reward points, you must provide the court with a specific monetary valuation (a 'valuation bridge') to ensure the judgment is legally complete and enforceable.

This question has been addressed in 1 Texas court opinion:

Vodicka v. Tobolowsky

COA05 — February 23, 2026

In Vodicka v. Tobolowsky, a judgment creditor sought to satisfy a multi-million dollar judgment by garnishing the debtors' airline miles. The Dallas Court of Appeals addressed whether service was effective under Rule 21a, whether Texas retained jurisdiction after the judgment was domesticated in Florida, and whether the trial court was required to value the miles. The court analyzed Rule 21a, concluding that service is legally complete upon deposit in the mail, and affirmed that Texas courts retain jurisdiction to enforce their judgments through ancillary proceedings. However, the court held that while airline miles are garnishable assets, the trial court committed reversible error by failing to assign them a specific monetary value. The case was remanded to determine the market value of the miles to ensure proper credit against the judgment balance.

Litigation Takeaway

“When enforcing a judgment or dividing property involving intangible assets like airline miles or reward points, you must provide the court with a specific monetary valuation (a 'valuation bridge') to ensure the judgment is legally complete and enforceable.”