Reeves v. Crownshield
Facts
A creditor sought to collect an approximately $400 judgment by using the 1935 statutory procedure allowing installment payments from a debtor's income. The debtor was employed by the Federal government as a steamship inspector earning $230 per month, less a small pension deduction; he had no children, his wife's whereabouts were unknown, and his only identified obligations were $48 monthly rent and living expenses. The court ordered him to pay $20 per month until the judgment was satisfied. When he failed to pay, he was held in contempt, fined $20, and made subject to commitment if he did not pay the fine.
Issue
Do sections 793 and 801 of the Civil Practice Act, which authorize installment payment orders from a judgment debtor's income and contempt sanctions for nonpayment, violate due process by effectively imposing imprisonment for debt? Does applying that procedure to a Federal employee unconstitutionally interfere with a Federal instrumentality?
Rule
Imprisonment for failure to obey a court order directing payment from income is not unconstitutional imprisonment for debt when the order is made with due regard to the reasonable needs of the debtor and his family and rests on the debtor's ability to comply. A State may require a Federal employee, after salary has been paid to him, to apply part of that income to satisfy a judgment, and contempt sanctions for disobeying such an order do not unlawfully interfere with a Federal instrumentality.
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If Devin is later cited for contempt for failing to make the ordered payments, what is the strongest argument for upholding the contempt sanction?