Michigan Law Review Volume 59 Issue 3 1961 Attachment and Garnishment in the Federal Courts Brainerd Currie The University of Chicago Follow this and additional works at: https://repository.law.umich.edu/mlr Part of the Civil Procedure Commons, Courts Commons, Jurisdiction Commons, and the Supreme Court of the United States Commons Recommended Citation Brainerd Currie, Attachment and Garnishment in the Federal Courts, 59 MICH. L. REV. 337 (1961). Available at: https://repository.law.umich.edu/mlr/vol59/iss3/2 This Article is brought to you for free and open access by the Michigan Law Review at University of Michigan Law School Scholarship Repository. It has been accepted for inclusion in Michigan Law Review by an authorized editor of University of Michigan Law School Scholarship Repository. For more information, please contact
[email protected]. MICHIGAN LAW REVIEW Vol 59 JANUARY 1961 No. 3 ATTACHMENT AND GARNISHMENT IN THE FEDERAL COURTS Brainerd Currie* I. TllE PROBLEM AND ITS ORIGINS ERSONAL injuries allegedly caused by the negligent manufac P ture of safety fuses used in blasting operations in a coal mine were suffered by Raymond Davis, apparently a citizen of Arkansas. The manufacturer, Ensign-Bickford Company, was a Connecticut corporation that could not be personally served with process within Arkansas. But it happened that two foreign corporations, ame nable to process in the state, were indebted in substantial amounts to Ensign-Bickford Company. Accordingly, counsel for Davis, in voking the diversity jurisdiction, filed an action in the District Court for the Western District of Arkansas. Without issue of sum mons, the plaintiff, in conformity with Arkansas statutes, sued out orders of general attachment, for notice by publication, and for warning the defendant.