United States Court of Appeals
                      For the First Circuit


No. 23-1290

               SECURITIES AND EXCHANGE COMMISSION,

                       Plaintiff, Appellee,

                                v.

               HAYDÉE YOLANDA SANCHEZ-DIAZ MONGE,

                   Relief Defendant, Appellant,

  LUIS JIMENEZ CARRILLO, AMAR BAHADOORSINGH, JUSTIN ROGER WALL,
                     and JAMIE SAMUEL WILSON,

                           Defendants,

     MARTHA Y. JIMENEZ TRUST and CHARLES A. CARRILLO TRUST,

                        Relief Defendants.


          APPEAL FROM THE UNITED STATES DISTRICT COURT
               FOR THE DISTRICT OF MASSACHUSETTS

          [Hon. William G. Young, U.S. District Judge]


                              Before

                  Kayatta, Howard, and Rikelman,
                          Circuit Judges.


     Brooks T. Westergard, with whom Jacob S. Frenkel and Dickinson
Wright PLLC were on brief, for appellant.

     Stephen Silverman, Appellate Counsel, with whom Megan
Barbero, General Counsel, Michael A. Conley, Solicitor, and Kerry
J. Dingle, Senior Appellate Counsel, were on brief, for appellee.
December 7, 2023
          RIKELMAN, Circuit Judge.       In 2009, Yolanda Sanchez-Diaz

divorced Luis Jimenez Carrillo and entered into a typical marital

termination   agreement,   which   included   child   support   for   the

couple's five-year-old son and limited spousal support for her.

After Carrillo moved away, they modified this agreement in 2016.

Under the modified terms, Sanchez-Diaz took full physical and legal

custody of their son and received increased child support and help

with other expenses, including a new car.

          In 2021, the Securities and Exchange Commission (SEC)

sued Carrillo for securities violations he allegedly committed

well after the couple divorced.     It named Sanchez-Diaz as a relief

defendant in the suit and sought to recover from her the value of

the new car she had received four years earlier, claiming Carrillo

paid for it with illicit funds.      The SEC did not accuse Sanchez-

Diaz of any wrongdoing but argued she had no legitimate claim to

the car because she had not provided any consideration for it.

The district court agreed and ordered her to pay almost $170,000,

including interest.   Because we conclude that the district court

applied the wrong legal standard in evaluating the SEC's arguments

and that Sanchez-Diaz provided value for the car by assuming full-

time care for the couple's son for six years, we reverse.




                                   -3-
                             I. BACKGROUND

                            A. Relevant Facts

           Sanchez-Diaz married Defendant Luis Jimenez Carrillo in

2001.   The couple lived in California and had one child, a son,

who was born in 2003.       In July 2009, Sanchez-Diaz and Carrillo

divorced   and   executed    a   marital   termination   agreement   in

California's San Diego Superior Court.          The agreement required

Carrillo to pay $1,500 per month in child support and $3,139 per

month in spousal support, with the last spousal support payment

due on August 1, 2012.        It also provided for shared physical

custody of their son, who at the time was five years old; Carrillo

took care of their son every other weekend, and the parents

alternated school holidays, vacations, and the son's birthday.       In

December 2009, Sanchez-Diaz and Carrillo executed an addendum to

the marital termination agreement that extended spousal support

payments for an additional six months, such that payments would

end in February 2013.

           In late 2013, Carrillo moved to Mexico.       Sanchez-Diaz,

who continues to reside in California, has had sole legal and

physical custody of their son since early 2014.

           In March 2016, when their son was almost thirteen years

old, Sanchez-Diaz and Carrillo executed in Mexico a m