National Maritime Services, Inc. v. Glenn F. Straub, 776 F.3d 783

National Maritime obtained a maritime judgment against Burrell Shipping for unpaid management/custodial services (≈ $99,660).
Burrell Shipping sold its sole asset (the vessel) and transferred the sale proceeds to its owner, Glenn F. Straub.
Straub is the sole owner and control-person of Burrell Shipping and related entities; Burrell Shipping was insolvent when the sale occurred.
After failing to collect from Burrell Shipping, National Maritime invoked Fed. R. Civ. P. 69 and Fla. Stat. § 56.29(6) in a supplementary proceeding seeking to void the transfer as fraudulent.
The district court found the transfer fraudulent under Fla. Stat. § 726.106(2) (transfer to an insider for antecedent debt while debtor insolvent and insider knew of insolvency) and entered judgment against Straub for the amount of the judgment.
On appeal the court reviewed (1) whether the district court had ancillary jurisdiction to hear the supplementary proceeding, and (2) whether the transfer was fraudulent; both issues were decided in favor of National Maritime.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court had ancillary jurisdiction to adjudicate a supplementary proceeding to avoid a fraudulent transfer	Ancillary jurisdiction permits the court to recapture assets fraudulently transferred by the judgment debtor that are held by a third party, to effectuate its judgment	Jackson-Platts (and related authority) shows such proceedings are a new action imposing liability on a third party and thus outside ancillary jurisdiction	Ancillary jurisdiction existed: the claim sought disgorgement of a transferred asset (not imposition of full judgment liability on a third party) and fits within ancillary power to protect/enforce federal judgments
Whether the transfer of sale proceeds to Straub was a fraudulent transfer under Florida law (UFJA/ UFTA)	Transfer was to an insider for antecedent debt while debtor insolvent; Straub knew or should have known of insolvency, so transfer is voidable under Fla. Stat. § 726.106(2)	Argues transfer was not without reasonably equivalent value and that Straub provided new value or consideration, so transfer is not voidable	District court’s factual findings upheld; transfer met § 726.106(2) elements. Arguments about ‘‘reasonably equivalent value’’ and ‘‘new value after transfer’’ fail as they do not defeat § 726.106(2) liability

Peacock v. Thomas, 516 U.S. 349 (1996) (describes limits of ancillary jurisdiction and distinguishes permissible remedies that recapture assets from impermissible suits imposing liability on third parties)
Kokkonen v. Guardian Life Ins. Co., 511 U.S. 375 (1994) (framework for ancillary jurisdiction: interdependent claims and court’s ability to enforce its decrees)
Jackson-Platts v. Gen. Elec. Capital Corp., 727 F.3d 1127 (11th Cir.) (discussed as not dispositive here because it involved attempts to impose full judgment liability on new parties)
Epperson v. Entm’t Express, Inc., 242 F.3d 100 (2d Cir. 2001) (upholding exercise of ancillary jurisdiction to avoid fraudulent transfers)
Thomas, Head & Griesen Emps. Trust v. Buster, 95 F.3d 1449 (9th Cir. 1996) (same; supports ancillary jurisdiction for fraudulently transferred assets)
Dewey v. West Fairmont Gas Coal Co., 123 U.S. 329 (1887) (early Supreme Court approval of ancillary jurisdiction to challenge fraudulent transfers to third parties)
Swift & Co. Packers v. Compania Colombiana Del Caribe, S.A., 339 U.S. 684 (1950) (admiralty authority affirming power to prevent fraudulent transfers that thwart jurisdiction)