From Casetext: Smarter Legal Research

Citizens Bank of Ashburn v. Shingler

Court of Appeals of Georgia
Feb 22, 1985
173 Ga. App. 511 (Ga. Ct. App. 1985)

Opinion

69603.

DECIDED FEBRUARY 22, 1985.

Garnishment. Tift Superior Court. Before Judge Gray, Senior Judge.

J. Harvey Davis, C. Paul Bowden, for appellant. John R. Rogers, Rob Reinhardt, for appellee.


Judgment debtor Martha Shingler traversed a garnishment proceeding instituted by the Citizens Bank of Ashburn against Great Southern Federal on the basis that the accounts in garnishee's possession were individual retirement accounts exempt from garnishment pursuant to OCGA § 18-4-22. The trial court sustained Shingler's traverse and Citizens Bank appeals.

The Congress, in establishing individual retirement accounts, 26 U.S.C. § 408 (a), under the umbrella of the comprehensive Employee Retirement Income Security Act of 1974 (ERISA), Pub.L. 93-406, 88 Stat. 829, provided that there was to be no alienation or assignment of benefits. 29 U.S.C. § 1056 (d) (1); see Mallory v. Mallory, 432 A.2d 950, 952 (1981). The assignment-alienation prohibition contained in ERISA extends to involuntary assignments such as garnishments. Commercial Mtg. Ins. v. Citizens Nat. Bank, 526 F. Supp. 510, 518 (1981). Furthermore, ERISA's assignment-alienation prohibition preempts otherwise relevant state law as it applies to claims by commercial creditors in non-bankruptcy situations against ERISA-qualified benefit plans. Id.; see also Mallory, supra; Matter of Goff, 706 F.2d 574, 584 (1983). Thus federal law pre-empts OCGA § 18-4-22 and mandates a finding that the individual retirement accounts possessed by garnishee are exempt from garnishment by appellant, a commercial creditor, in this non-bankruptcy situation.

The trial court did not err by sustaining appellee's traverse to appellant's affidavit of garnishment.

Judgment affirmed. Deen, P. J., and McMurray, P. J., concur.

DECIDED FEBRUARY 22, 1985.


Summaries of

Citizens Bank of Ashburn v. Shingler

Court of Appeals of Georgia
Feb 22, 1985
173 Ga. App. 511 (Ga. Ct. App. 1985)
Case details for

Citizens Bank of Ashburn v. Shingler

Case Details

Full title:CITIZENS BANK OF ASHBURN v. SHINGLER

Court:Court of Appeals of Georgia

Date published: Feb 22, 1985

Citations

173 Ga. App. 511 (Ga. Ct. App. 1985)
326 S.E.2d 861

Citing Cases

Strickland v. Alexander

See O.C.G.A. § 18–4–93 (providing that the debtor “may become a party to the garnishment for the purposes set…

Mackey v. Lanier Collection Agency c., Inc.

Under the Shaw analysis, OCGA § 18-4-22.1 would not be preempted since it does not prohibit practices that…