Reeves v. Motor Contract Company of Georgia

324 F. Supp. 1011, 1971 U.S. Dist. LEXIS 13970
CourtDistrict Court, N.D. Georgia
DecidedMarch 29, 1971
DocketCiv. A. 14156
StatusPublished
Cited by8 cases

This text of 324 F. Supp. 1011 (Reeves v. Motor Contract Company of Georgia) is published on Counsel Stack Legal Research, covering District Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reeves v. Motor Contract Company of Georgia, 324 F. Supp. 1011, 1971 U.S. Dist. LEXIS 13970 (N.D. Ga. 1971).

Opinion

PER CURIAM:

The plaintiff in this action petitions the court to hold unconstitutional the Georgia garnishment in attachment procedure as violative of his due process, equal protection, and First Amendment rights. Jurisdiction is conferred pursuant to 42 U.S.C. § 1983, 28 U.S.C. §§ 1343(3), 2201 and 2202. A three-judge court was constituted in accordance with 28 U.S.C. §§ 2281 and 2284, inasmuch as plaintiff sought to enjoin the enforcement of a state statute as against himself and the class he represents.

The pertinent facts here reflect that the plaintiff, in 1969, financed the purchase of an automobile through a loan from the defendant, Motor Contract Company of Georgia (hereinafter referred to as “Motor Contract”). Several months thereafter, when the plaintiff defaulted in his payments on the loan, Motor Contract repossessed the vehicle at the plaintiff’s place of employment. While there exists some dispute as to the order in which Motor Contract attempted to locate the plaintiff by mail," i.e., whether before or after the repossession, it is apparent that Motor Contract’s written attempts in this regard remained unanswered by the plaintiff. On August 11, 1970, the plaintiff’s employer notified him that his wages had been garnished through the Civil and Criminal Court of Clayton County, Georgia. After consulting with his present counsel, the plaintiff learned that no action was then pending in the Civil Court of Fulton County, plaintiff’s county of residence. As a consequence thereof, plaintiff brought this action for injunctive and declaratory relief from the allegedly unconstitutional application of the Georgia scheme for garnishment under authority of Georgia Code Ann. §§ 46-101, 8-501, et seq., 8-204, 8-205 and 46-402. 1

*1014 Prior to the filing of briefs by the defendants, counsel for Motor Contract discovered that the proceedings before the Civil and Criminal Court of Clayton County were null and void, because the affidavit required by statute, Ga.Code Ann. § 8-109, was improperly executed. See, Heard v. National Bank of Illinois, 114 Ga. 291, 40 S.E. 266 (1901); Jenkins v. Community Loan & Investment Corp. of Savannah, 120 Ga.App. 543, 171 S.E.2d 654 (1969); Kazakos v. Soteres, 120 Ga.App. 258, 170 S.E.2d 50 (1969). In recognition of this fact, all proceedings before the court in Clayton County were dismissed by Motor Contract. The outstanding temporary restraining order first issued by this court on September 11, 1970, and continued on September 22, 1970, was thereafter dissolved on November 23, 1970, the defendant, Joe B. Mundy, being required to pay over to the plaintiff any funds then on deposit with that court.

At the hearing on November 23, 1970, the court heard oral argument by counsel primarily on the question of mootness. While counsel for the plaintiff concede that his claim for injunctive relief was mooted by Motor Contract’s dismissal in the state court, we reserved judgment on whether the dismissal was sufficient to also moot plaintiff’s claim for declaratory relief and damages. We are of the opinion that there remains a sufficient controversy in this case worthy of federal court adjudication.

The defendants contend that the state court dismissal of the garnishment proceedings evidences the lack of justiciability persisting in the cause now pending. The argument is made that the court would be acting upon a hypothetical situation which might never recur, since Motor Contract may not, under the above Georgia statutes, refile a similar suit until the circumstances which justified the prior suit present themselves *1015 anew. In other words, pursuant to Ga. Code Ann. § 8-101, 2 the plaintiff must fall within one of the six statutory exceptions before garnishment in attachment becomes an available remedy.

While we find some merit to these contentions of defendants, we feel the better line of cases support the conclusion that a,

* * * voluntary cessation of allegedly illegal conduct does not deprive the tribunal of power to hear and determine the case, i. e., does not make the case moot, [citations omitted] * * * The case may nevertheless be moot if the defendant can demonstrate that “there is no reasonable expectation that the wrong will be repeated.”

United States v. W. T. Grant Co., 345 U.S. 629, 632-633, 73 S.Ct. 894, 897, 97 L.Ed. 1303 (1952). The defendants, in the instant case, have not sustained their burden by demonstrating to the court that the contested situation may not recur upon the dismissal of this suit. Motor Contract is in no way constrained from commencing another, albeit invalid, garnishment proceeding in the state courts, and thereby freezing the plaintiff’s wages until the final determination thereof or the filing of a bond as permitted by the statute. This freedom to “return to the old ways” is what makes the present action retain its justiciability. Therefore, the defendants' argument in favor of dismissal for mootness is hereby denied.

An examination of the pertinent statutes reveals that Georgia recognizes the garnishment in attachment procedure as an exception to the general prohibition against prejudgment garnishment. Ga. Code Ann. § 46-101. The state argues that the six extraordinary circumstances justifying prejudgment garnishment, Ga.Code Ann. §§ 8-101, 8-501, distinguish this case from that before the Court in Sniadach v. Family Finance Corp., 395 U.S. 337, 89 S.Ct. 1820, 23 L.Ed.2d 349 (1969), in that the situations contemplated by the statute negate the feasibility of having a prior hearing on the merits. Specifically, as applied to the plaintiff, the contention is made that were he truly “concealing himself”, as required by Section 8-101(4), then service of process followed by a hearing would by definition be impossible. Since the debtor’s whereabouts would be unknown to the creditor, the statute envisions the only practical manner by which the underlying debt may effectively be satisfied.

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Bluebook (online)
324 F. Supp. 1011, 1971 U.S. Dist. LEXIS 13970, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reeves-v-motor-contract-company-of-georgia-gand-1971.