Harris v. Balk

In Harris v. Balk, 198 U.S. 215, 221, 25 S. Ct. 625, 49 L. Ed. 1023 (1905), relied on by the State in this case, the Court considered whether Maryland had jurisdiction to garnish a debt owed by North Carolina resident Harris to North Carolina resident Balk in order to satisfy a debt owed by Balk to Maryland resident Epstein. Epstein had commenced the garnishment proceeding by serving Harris with a writ of attachment while Harris was visiting Maryland. Id. In concluding that Maryland possessed jurisdiction to garnish the debt owed by Harris to Balk, the Court reasoned that "the obligation of the debtor to pay his debt clings to and accompanies him wherever he goes." Id. Because Balk had the right to sue Harris in Maryland to recover the debt while Harris was temporarily in that state and its courts could exercise in personam jurisdiction over him, the Court concluded that Epstein could likewise garnish that debt through the Maryland courts. Id. at 223-24, 226.