Bowles v. Goss, 309 P.3d 150

Bowleses obtained a judgment against Goss on April 21, 2006 and recorded a lien on Goss's property.
Goss sought federal bankruptcy relief but was denied due to the judgment arising from fraud.
April 15, 2011 district court order required Goss to appear and answer as to assets and barred transfers of nonexempt assets.
May 12, 2011, Bowleses conducted a hearing on assets; results memorialized in the July 18, 2011 order.
Goss filed a motion to reconsider the July 2011 order within ten days; the motion was denied.
Goss sought appellate review challenging security, breadth of the lien, and authority to enjoin transfers encumbrances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether security was required for the injunction	Goss argues no security was posted as required by 12 O.S.754? § 1392.	Bowleses contend§ 1392 applies, and security must be posted.	Security requirement not controlling; otherwise the order stands.
Whether all assets (including homestead) are subject to the lien	Lien attaches to all real property; homestead exempt from forced sale but lien still valid.	Homestead exemptions should shield principal residence from execution.	All assets, including homestead, are subject to the Bowleses' lien; exemptions apply only to sale, not to liability.
Whether the district court had authority to enjoin transfers/encumbrances post-hearing	Post-hearing injunctions were beyond statutory authorization.	Inherent power and § 850 authorize enforcement and injunctions to satisfy judgment.	District court had statutory authority and inherent power to prohibit transfers/encumbrances.
Whether the $31,000 line of credit proceeds are reachable	All funds from nonexempt sources should be applied to the judgment.	Limited reach; some use may be exempt if used to reinvest in a new homestead per Harrell.	Affirmed to the extent proceeds are used to satisfy judgment; modified to permit hearing on reinvestment in a new homestead.

Horizons, Inc. v. Keo Leasing Co., 681 P.2d 757 (Okla. 1984) (motion for new trial limits issues on appeal)
Samman v. Multiple Injury Trust Fund, 33 P.3d 302 (Okla. 2001) (de novo review of statutory questions)
Heffron v. District Court of Oklahoma County, 77 P.3d 1069 (Okla. 2003) (de novo review for statutory interpretation)
Mid-America Corp. v. Geismar, 380 P.2d 85 (Okla. 1963) (equitable discretion in post-judgment relief)
Capshaw v. Gulf Ins. Co., 107 P.3d 595 (Okla. 2005) (abuse of discretion standard for new trial rulings)
Spencer v. Oklahoma Gas & Electric Co., 171 P.3d 890 (Okla. 2007) (abuse of discretion standard in installment orders)
Ramco Operating Co. v. Gassett, 890 P.2d 941 (Okla. 1995) (judgment debtor’s property available to satisfy judgment)
Toma v. Toma, 163 P.3d 540 (Okla. 2007) (homestead proceeds and reinvestment requirements under Harrell framework)
Harrell v. Bank of Wilson, 445 P.2d 266 (Okla. 1968) (good faith reinvestment necessary for homestead proceeds exempt status)
Winters By and Through Winters v. City of Oklahoma City, 740 P.2d 724 (Okla. 1987) (inherent powers of courts to enforce judgments)