Livingston v. Naylor (Ct. of Special Appeals)

Filed March 30, 2007 Opinion by Judge Timothy Meredith

Livingston appealed from an order denying his motion to dismiss a writ of garnishment of his wages. Naylor had obtained a money judgment against Livingston in North Carolina and then enrolled that judgment in Maryland pursuant to the Uniform Enforcement of Foreign Judgments Act. As a resident of North Carolina, Livingston argued that the Maryland court did not have an adequate basis to exercise personal jurisdiction over him. The Court of Special Appeals held that there were sufficient contacts for jurisdiction over Livingston and Maryland courts could garnish Livingston’s property in Maryland, including compensation he earned from Marriott for services Livingston rendered in Maryland. Due process, however, would not permit garnishment in Maryland of compensation Livingston earned for services rendered wholly outside of Maryland when the garnishment order was based solely on the fact that Livingston’s employer does business in Maryland.