Georgia Court of Appeals
Sms Financial Recovery Services, LLC v. Yaarit Silverstone
A26A0482
April 30, 2026
Reversed
Automated case summary
What the court decided
The issue at hand is whether OCGA § 9-15-14 applies to garnishment proceedings. Key facts include that SMS Financial Recovery Services, LLC filed a garnishment proceeding seeking to recover a judgment against Ian Silverstone, and Yaarit Silverstone filed a third-party claim asserting ownership of the funds in the bank account. The holding is that OCGA § 9-15-14 does not apply to garnishment proceedings because they are special statutory proceedings rather than civil actions.