ProData Computer Services, Inc. v. Ponec

Ronald Ponec (defendant), a ProData co-founder, repeatedly diverted company funds to his own use through improper checks, direct payments, and depositing customer checks into his personal accounts; after a jury awarded ProData (plaintiff) roughly $580,000 for fraud, conversion, and related claims, the trial court imposed a constructive trust on Ponec's investment accounts holding the traced converted funds, and Ponec appealed, arguing the accounts predated the deposits and the funds had since appreciated.