In Low v. Henry, 221 S.W.3d 609 (Tex. 2007), a widow sued two physicians, Robert Low and Stephen Smith, for damages relating to her husband's death. See id. at 613. Low and Smith filed motions for sanctions against the widow's attorney, Thomas J. Henry, for alleged violations of Chapter 10. The widow's lawsuit was subsequently nonsuited. Following a hearing on the physicians' motions, the trial court ordered Henry to pay $25,000 in sanctions on each motion, for a total of $50,000. Id. Those penalties were "not based on expenses, court costs, or attorney's fees." Id. at 614. The court of appeals reversed the sanctions award, concluding (1) the evidence did not support sanctions under Chapter 10 and (2) the trial court's order failed to meet the specificity requirements of that chapter. Id. The supreme court disagreed with the court of appeals in part. Id. at 619-20. Specifically, the supreme court concluded the evidence supported an award of sanctions under Chapter 10. However, as to the amount of the sanctions against Henry, that court stated in part, "Although this Court has not specifically identified factors for a trial court to consider when assessing penalties under Chapter 10, the absence of an explanation of how a trial court determined that amount of sanctions when those sanctions are especially severe is inadequate." Id. at 620. Then, quoting from a 1988 report of the American Bar Association, the supreme court described a "nonexclusive list" of factors "helpful in guiding the often intangible process of determining a penalty for sanctionable behavior." Id. Further, that court stated: "Although we do not require a trial court to address all of the factors listed in the report to explain the basis of a monetary sanction under Chapter 10, it should consider relevant factors in assessing the amount of the sanction. In addition, the determination of the amount of a penalty to be assessed under Chapter 10, which is not limited to attorney's fees and costs, should nevertheless begin with an acknowledgement of the costs and fees incurred because of the sanctionable conduct. This provides a monetary guidepost of the impact of the conduct on the party seeking sanctions and the burden on the court system." Id. at 621. The supreme court observed that the physicians' testimony did not quantify the expense of claimed loss of work time or identify any other out-of-pocket expenses. Id. at 621. That court concluded (1) "we cannot determine the basis of the $50,000 penalty on this record" and (2) "the trial court abused its discretion in not more specifically identifying the basis for imposing a $50,000 penalty under chapter 10." Id. at 621-22. The judgment of the court of appeals was reversed and the case was remanded to the trial court to allow the parties to present further evidence and allow the trial court "to consider the amount of the penalty imposed in light of the guidelines in this opinion." Id.