In Brown v. Liberty Loan Corp., the Court of Appeals for the Fifth Circuit held that Florida's post-judgment garnishment statutes satisfy due process requirements even though they fail to provide the judgment debtor with notice and an opportunity for a hearing on his entitlement to a statutory wage exemption before wages are attached.
Porter, Robert L. Jr.
"Post-Judgment Garnishment Without Notice And a Hearing Is Constitutional,"
Mercer Law Review: Vol. 28:
4, Article 14.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol28/iss4/14