Susan Guinta is a real estate salesperson. Smythe Cramer Co. went to an Ohio state court and obtained a garnishment order to attach Guintas personal earnings. The order was served on Russell Realtors to attach sales commissions that Russell owed to Guinta. Russell objected, arguing that commissions are not personal earnings and are therefore exempt from attachment under a garnishment of personal earnings. An Ohio statute defi nes personal earnings as money, or any other consideration or thing of value,