Richard Pamplin and Networth Cashflow Systems, LLC v. Kelly Stephenson, Trustee of the Coffee Time, Inc. 40 I K (PSP), 04-21-00208-CV

In 2011 a Kansas court entered default judgment against Richard Pamplin and Networth Cashflow Systems, LLC for about $99,000; the judgment was domesticated in Bexar County, Texas.
The Texas trial court entered a turnover order and appointed a receiver (2014); a substitute receiver was later appointed.
The receiver seized commission payments payable to Pamplin from LifeVantage, a multilevel-marketing company that pays distributors via a Sales Compensation Plan.
LifeVantage reported payments to Pamplin on Form 1099 and Pamplin reported the receipts on Schedule C as business income; he did not receive a W-2.
In January 2021 the receiver moved to approve distribution of the seized LifeVantage funds to judgment creditor Kelly Stephenson; Pamplin objected and appealed after the trial court approved the distribution.
The court of appeals held it had jurisdiction (the distribution order operated as a mandatory injunction resolving property rights) and affirmed that the LifeVantage payments were not exempt as wages or commissions for personal services.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appealability: whether the post-judgment distribution order is an appealable mandatory injunction	Pamplin: the distribution order determined his property rights and functioned as a mandatory injunction, so it is final and appealable	Receiver/Stephenson: the order merely enforced the prior turnover order and was administrative/nonadjudicative, not appealable	Court: order was the first judicial determination of competing ownership rights, operated as a mandatory injunction, and was appealable
Exemption: whether LifeVantage payments were exempt as wages or unpaid commissions for personal services under Tex. Prop. Code § 42.001	Pamplin: payments are current wages or unpaid commissions for personal services and therefore exempt	Receiver/Stephenson: Pamplin was an independent contractor; payments are business/commercial commissions, not personal-service wages or exempt commissions	Court: evidence supports that payments were commissions to an independent distributor, not compensation for personal services; thus not exempt

Alexander Dubose Jefferson & Townsend LLP v. Chevron Phillips Chem. Co., L.P., 540 S.W.3d 577 (Tex. 2018) (post-judgment turnover that first determines ownership rights can be appealable as a mandatory injunction)
Transcon. Realty Inv’rs, Inc. v. Orix Capital Markets LLC, 470 S.W.3d 844 (Tex. App.—Dallas 2015) (portion of post-judgment turnover resolving property rights and imposing third-party obligations is appealable)
Schultz v. Fifth Judicial Dist. Court of Appeals at Dallas, 810 S.W.2d 738 (Tex. 1991) (denial of appellate review would leave affected property interests unprotected)
Beaumont Bank, N.A. v. Buller, 806 S.W.2d 223 (Tex. 1991) (abuse-of-discretion standard for turnover/injunctive relief review)
Campbell v. Stucki, 220 S.W.3d 562 (Tex. App.—Tyler 2007) (‘‘current wages for personal service’’ implies employer-employee relationship; excludes independent contractors)
Leibman v. Grand, 981 S.W.2d 426 (Tex. App.—El Paso 1998) (unpaid commissions exempt only if for personal services)
Brasher v. Carnation Co. of Tex., 92 S.W.2d 573 (Tex. App.—Austin 1936) (same: exemption requires master-servant relationship)
Goebel v. Brandley, 174 S.W.3d 359 (Tex. App.—Houston [14th Dist.] 2005) (Property Code § 42.001 exempts current wages for personal services)