## Facts

- A New York City court entered a money judgment of about $400 against Harry N. Reeves.
- In supplementary proceedings, Reeves’s income was disclosed: he worked as a federal steamship inspector earning $230 per month (minus a small pension deduction).
- Reeves had no children; his wife’s whereabouts were unknown; his stated rent was $48 per month, and he reported no other significant obligations.
- Under Civil Practice Act § 793 (1935), the court ordered Reeves to pay $20 per month from his income toward the judgment, after procedures requiring notice and an opportunity to show inability to pay.
- Reeves did not make the ordered payments.
- Under Civil Practice Act § 801, the court adjudged Reeves in contempt, fined him $20, and provided for commitment in default of payment.
- Reeves challenged the installment-payment and contempt scheme as unconstitutional imprisonment for debt and a violation of the Fourteenth Amendment’s Due Process Clause; he did not claim the $20 amount was unfair, only that the court lacked power to compel payment from income.

## Issues

1. Whether a court may constitutionally order a judgment debtor to pay installments from income toward a money judgment, after notice and an opportunity to show inability to pay.
2. Whether punishing a willful failure to comply with such an installment-payment order as contempt constitutes unconstitutional imprisonment for debt or violates due process.

## Decision

- The Court of Appeals of New York affirmed the installment-payment order and the contempt adjudication.
- The court held that enforcing an installment order through contempt, where the debtor has the ability to comply and the order accounts for reasonable needs, does not violate due process.
- The court characterized the sanction as punishment for disobedience of a lawful court order, not imprisonment for debt.

## Legal Principles

- A statute permitting installment-payment orders from a judgment debtor’s income is constitutional when entered on notice, after an opportunity to show inability to pay, and with regard to the debtor’s reasonable requirements and obligations to other creditors.
- A willful refusal to comply with a valid installment-payment order may be punished as contempt without constituting prohibited imprisonment for debt, so long as the debtor is able to comply.
- Due process is satisfied where the debtor receives notice and a chance to contest ability to pay before an installment order issues, and contempt is based on disobedience of that order.

## Conclusion

The court upheld New York’s installment-payment enforcement procedure and confirmed that contempt sanctions for a debtor’s willful noncompliance with a payment order—issued with procedural safeguards and tied to the debtor’s ability to pay—are constitutionally permissible and are not imprisonment for debt.


Matter of Reeves v. Crownshield, 274 N.Y. 74, 8 N.E.2d 283 (N.Y. 1937)