Flack v. State of New York

In Flack v. State of New York (95 NY 461, 5 Civ. Proc. R. 286 (1884)), the Court stated that in order "to bring the claim of a sheriff within the provisions of the statute, it is essential that he or she show either the collection of the moneys called for, or some interference by the plaintiff judgment creditor with his execution of the process that is equivalent thereto" (id. at 466).