TRUIST BANK F/K/A BRANCH BANKING AND TRUST COMPANY v. GORDON D. STARK

CourtCourt of Appeals of Georgia
DecidedMarch 16, 2021
DocketA20A2000
StatusPublished

This text of TRUIST BANK F/K/A BRANCH BANKING AND TRUST COMPANY v. GORDON D. STARK (TRUIST BANK F/K/A BRANCH BANKING AND TRUST COMPANY v. GORDON D. STARK) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TRUIST BANK F/K/A BRANCH BANKING AND TRUST COMPANY v. GORDON D. STARK, (Ga. Ct. App. 2021).

Opinion

SECOND DIVISION MILLER, P. J., MERCIER, J., and SENIOR APPELLATE JUDGE PHIPPS.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

March 5, 2021

In the Court of Appeals of Georgia A20A2000. TRUIST BANK f/k/a BRANCH BANKING AND TRUST COMPANY v. STARK.

PHIPPS, Senior Appellate Judge.

Truist Bank appeals from a final judgment of the trial court in which it found

that approximately $104,000 in an account held by Gordon Stark was subject to the

twenty-five percent disposable earnings limitation on garnishment under former

OCGA § 18-4-5 (a) (1).1 For the reasons that follow, we reverse.

Appellate courts review factual determinations in a garnishment proceeding

under the “any evidence” standard and we are bound by the trial court’s findings as

long as there is any evidence to support them. A. M. Buckler & Assoc., Inc. v.

1 The current version of OCGA § 18-4-5 took effect in January 2021. Throughout this opinion, all citations to OCGA § 18-4-5 will refer to the prior version in effect in 2019, at the time this garnishment action was initiated. Sanders, 305 Ga. App. 704, 707-708 (1) (700 SE2d 701) (2010). But “[w]hen the

evidence is uncontroverted and no question of witness credibility is presented . . . the

trial court’s application of the law to undisputed facts is subject to de novo appellate

review.” Stoker v. Severin, 292 Ga. App. 870, 871 (665 SE2d 913) (2008).

So viewed, the record shows that Truist obtained a judgment against Stark in

the amount of $768,663.47. In December 2019, Truist filed a garnishment action

naming Wells Fargo Bank, a financial institution, as the garnishee and seeking funds

in Stark’s account. Wells Fargo filed an answer to the garnishment, stating that it held

$129,968.74 of Stark’s money, which it then paid into the trial court’s registry. Stark

filed a claim asserting that $104,318.62 of the funds in his account were “exempt

from garnishment by virtue of being retirement benefits” pursuant to the provisions

of OCGA § 18-4-5.2 The parties do not dispute that the remaining $25,650.12 in the

account is subject to garnishment.

The trial court held a trial on Stark’s claim. Stark introduced evidence that he

received the $104,318.62 at issue from the ManpowerGroup Nonqualified Savings

Plan as a lump sum on July 2, 2019, following his separation from employment with

2 The written pleadings in the record state that the disputed amount is $104,318.62, while at trial, the amount was repeatedly referred to as $104,318.52.

2 ManpowerGroup. Stark also introduced a copy of the savings plan summary, which

stated that it “is intended to be an unfunded plan that provides deferred compensation

benefits for a select group of management or highly compensated employees of

ManpowerGroup.” The parties argued over whether the funds were subject to the

disposable earnings limitation in OCGA § 18-4-5 (a) (1).

At the conclusion of the trial, the court issued an order finding that the

disposable earnings limitation applied to the lump sum payment of $104,318.62.

Accordingly, the trial court ruled that Truist was entitled to garnish no more than

$51,729.77, which constitutes the sum of the $25,650.12 that Truist and Stark agreed

was not subject to any garnishment exemption or limitation, plus twenty-five percent

of the $104,318.62. The trial court ordered disbursement of the remaining funds in

the registry to Stark.

Truist filed an application for a discretionary appeal, which this Court granted.

Thereafter, Truist filed a timely notice of appeal.

1. Truist argues that the trial court erred in ruling that the disposable earnings

limitation applies to funds from an unfunded plan as described in OCGA § 18-4-6 (a)

(3). We agree.

3 To resolve this issue, we must analyze the interplay between OCGA §§ 18-4-5

(a) (1), 18-4-6 (a) (2), and 18-4-6 (a) (3). We note at the outset, however, that the

parties do not dispute that funds from this type of account are subject to the

provisions of OCGA § 18-4-6 (a) (3).

Under Georgia’s garnishment statutory scheme,”[a]ll money or other property

of the defendant in the possession or control of the garnishee . . . shall be subject to

the process of garnishment[.]” OCGA § 18-4-4 (b). But some property is exempt from

garnishment. Pertinent to this appeal, OCGA § 18-4-6 (a) states:

(1) Certain earnings or property of the defendant may be exempt from the process of garnishment.

(2) Funds or benefits from an individual retirement account or from a pension or retirement program shall be exempt from the process of garnishment until paid or otherwise distributed to a member of such program or beneficiary thereof. Such funds or benefits, when paid or otherwise distributed to such member or beneficiary, shall be exempt from the process of garnishment only to the extent of the limitations provided in Code Section 18-4-5 for other disposable earnings, unless a greater exemption is otherwise provided by law.

(3) Funds in an unfunded plan maintained by an employer primarily for the purpose of providing deferred compensation for a select group of

4 management or highly compensated employees shall not be exempt from the process of garnishment.

With respect to property that is subject to garnishment, OCGA § 18-4-5 (a) sets

out a disposable earnings limitation, stating:

(1) Subject to the limitations set forth in Code Section[] 18-4-6 . . . the maximum part of disposable earnings for any work week which is subject to garnishment shall not exceed the lesser of:

(A) Twenty-five percent of the defendant’s disposable earnings for that week;

or

(B) The amount by which the defendant’s disposable earnings for that week

exceed $217.50.

(2) In case of earnings for a period other than a week, the proportionate fraction or

multiple of 30 hours per week at $7.25 per hour shall be used.

Truist argues that because the funds described OCGA § 18-4-6 (a) (2) are

explicitly limited by the disposable earnings limitation in OCGA § 18-4-5, and no

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Stoker v. Severin
665 S.E.2d 913 (Court of Appeals of Georgia, 2008)
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494 S.E.2d 299 (Court of Appeals of Georgia, 1997)
State v. Free at Last Bail Bonds
647 S.E.2d 402 (Court of Appeals of Georgia, 2007)
A. M. Buckler & Associates, Inc. v. Sanders
700 S.E.2d 701 (Court of Appeals of Georgia, 2010)
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TRUIST BANK F/K/A BRANCH BANKING AND TRUST COMPANY v. GORDON D. STARK, Counsel Stack Legal Research, https://law.counselstack.com/opinion/truist-bank-fka-branch-banking-and-trust-company-v-gordon-d-stark-gactapp-2021.