In 1976, Malvern Bell married Frances Miller Wynn. In 1995, Malvern Bell died while Frances Snyder was living in a convalescence home in Tennessee. In settling Malvern's estate, law suits arose between Janet Snyder, Frances's daughter from a previous marriage, and William G. Bell, the personal representative of Malvern's estate. Ms. Snyder also sued the estate for, among other things, civil theft of a $122,634.59 check made payable to Frances Bell. William Bell counterclaimed against Ms. Snyder for conversion and spoliation of evidence. Bell claimed that Ms. Snyder had removed and concealed Malvern Bell's financial records. Both parties were awarded damages on their respective claims. However, the trial court denied Snyder's request for treble damages on the civil theft charge. The Second District Court of Appeal reversed, holding that Snyder was entitled to treble damages against the estate.