1. In SNIADACH v. FAMILY FINANCE CORP. OF BAY VIEW, 395 U.S. 337, 89 S.Ct.

1820, 23 L.Ed.2d 349 (1969), the Court struck down the Wisconsin wage garnishment procedure as violative of due process. The statute authorized a summons to issue at the request of the creditor’s lawyer; service on the garnishee froze the debtor’s wages during the period before trial and the wage earner had no opportunity to be heard prior to the garnishment. The Court explained:

A prejudgment garnishment of the Wisconsin type is a taking which may impose tremendous hardship on wage earners with families to support. Until a recent act of Congress, * * * which forbids discharge of employees on the ground that their wages have been garnished, garnishment often meant the loss of a job. Over and beyond that was the great drain on family income.