In the case of Wesley Williams, Garnishee of Edward F. Mahone, Plaintiff in Error v. Hill, McLane & Co., the Supreme Court was asked to determine whether a garnishment order issued by a state court could be enforced against an out-of-state defendant who had not been served with process or given notice of the proceedings. The plaintiff argued that since he had obtained a valid judgment from his home state's court and then properly issued a garnishment order against an out-of-state defendant, it should be enforceable regardless of service or notice requirements. However, the Supreme Court disagreed and held that due process requires all parties to have proper notice before any action can take place; thus, without proper service or notification being provided to Hill McLane & Co., they were not bound by the terms set forth in the garnishment order and could not be forced to comply with it.

In the dissenting opinion of Wesley Williams, Garnishee of Edward F. Mahone v Hill, McLane & Co., Justice Grier argued that a garnishment was not an appropriate remedy for the plaintiff in this case. He reasoned that since the defendant had already been served with process and failed to appear or answer, it would be unjust to allow them another opportunity to do so through a garnishment proceeding. Furthermore, he noted that such proceedings were only intended as a means of protecting creditors from debtors who could not otherwise be reached by service of process; thus they should not apply when there is no dispute between creditor and debtor over payment or other matters related thereto. Finally, Grier concluded that allowing such proceedings in cases where there is no dispute between parties would lead to unnecessary delays and expense for all involved without any benefit being realized by either party.