Sniadach v. Family Finance Corp.
395 U.S. 337 (1969)
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Rule of Law:
Absent notice and a prior opportunity to be heard, a state's prejudgment wage garnishment procedure violates the fundamental principles of procedural due process required by the Fourteenth Amendment.
Facts:
- Respondents alleged that petitioner Sniadach owed them $420 on a promissory note.
- Respondents initiated a garnishment action against Sniadach and her employer, Miller Harris Instrument Co.
- Under Wisconsin law, the respondents' attorney served a summons on Sniadach's employer, which immediately froze half of her earned wages.
- The employer stated it held $63.18 in earned wages and would pay half to Sniadach as a subsistence allowance, holding the other half ($31.59) subject to court order.
- Sniadach was served with the summons and complaint on the same day as her employer.
- Sniadach was a resident of the Wisconsin community, and personal jurisdiction was readily obtainable over her.
Procedural Posture:
- Respondents instituted a garnishment action in a Wisconsin lower court against petitioner Sniadach and her employer.
- Sniadach moved to dismiss the garnishment proceedings, arguing the procedure violated the Fourteenth Amendment's Due Process Clause.
- The lower state court denied the motion to dismiss.
- Sniadach appealed the lower court's decision to the Wisconsin Supreme Court.
- The Wisconsin Supreme Court affirmed the lower court's ruling, upholding the garnishment procedure.
- Sniadach (petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a state statute that allows for the prejudgment garnishment of wages without providing the debtor with prior notice and an opportunity to be heard violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Mr. Justice Douglas
Yes. A state's prejudgment wage garnishment procedure that deprives a debtor of earned wages without prior notice and a hearing violates the Due Process Clause of the Fourteenth Amendment. The Court reasoned that wages are a specialized type of property, the deprivation of which imposes tremendous hardship on wage earners and their families. While summary procedures may be permissible in extraordinary situations requiring special protection for a state or creditor interest, this case presented no such situation. The Court emphasized that the right to be heard has little value unless one can contest a claim before the deprivation occurs, and the Wisconsin procedure allows a taking of property without any opportunity for the wage earner to raise defenses beforehand.
Concurring - Mr. Justice Harlan
Yes. The temporary deprivation of the use of garnished wages is a deprivation of 'property' that is not de minimis and therefore must be accompanied by the procedural due process requisites of notice and a prior hearing. The core of due process is to establish the probable validity of the underlying claim before a person is deprived of their property or its unrestricted use. The fact that the deprivation is temporary or that the debtor was notified simultaneously with the garnishment does not satisfy the constitutional requirement for a pre-deprivation hearing aimed at establishing the validity of the creditor's claim.
Dissenting - Mr. Justice Black
No. The Wisconsin statute does not violate the fundamental principles of due process. The Court is acting as a 'super-legislative body' by striking down a state law based on its own policy judgments about the wisdom of garnishment, which is a role reserved for legislatures. The dissent argued that the garnishment was a temporary measure that merely preserved the status quo pending a full hearing on the merits, where the debtor could present all defenses. Citing historical precedent and prior Court decisions upholding similar attachment laws, the dissent asserted that such procedures have long been considered constitutional and the Court was improperly overruling its own precedents based on 'emotional rhetoric' rather than constitutional text.
Analysis:
This landmark decision significantly strengthened procedural due process rights for debtors. By requiring notice and a hearing before the garnishment of wages, Sniadach curtailed a powerful creditor remedy that had been widely used. The case established that wages are a special category of property deserving heightened protection and shifted the balance of power toward consumers in debt disputes. This ruling paved the way for subsequent cases, such as Fuentes v. Shevin, which extended the pre-deprivation hearing requirement to other forms of property, fundamentally altering the landscape of consumer credit law.
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