Sixth Circuit: Oklahoma Debt Firm's Wage Garnishment of Michigan Worker Establishes Personal Jurisdiction in Forum State

The underlying dispute began when Alexander Ross and his then-wife bought a used 2014 Toyota Scion Xb from a Tulsa dealership in February 2018. After the couple divorced and Ross moved to Michigan in July 2019, the car remained in Oklahoma with his ex-wife. When the former couple fell behind on payments, the creditor, Auto Advantage Finance LLC, repossessed the vehicle and hired Robinson, Hoover & Fudge, PLLC (RHF), an Oklahoma-based law firm, to pursue a breach-of-contract action in Oklahoma state court. Ross defaulted, and RHF obtained a default judgment in December 2022. By that point, RHF already knew Ross had relocated to Michigan. It then used the Oklahoma judgment to submit garnishment summonses to entities it believed employed Ross, ultimately reaching Detroit Diesel Corporation, a Michigan employer. As of June 2024, over $2,500 had been garnished from wages Ross earned working for Detroit Diesel, with garnishments continuing.

Ross filed a putative class action in the Eastern District of Michigan, alleging that RHF violated the Fair Debt Collection Practices Act and the Michigan Regulation of Collection Practices Act by garnishing his wages without first domesticating the Oklahoma judgment under Michigan's Uniform Enforcement of Foreign Judgments Act. The district court dismissed for lack of personal jurisdiction, concluding that RHF had insufficient contacts with Michigan.

The Sixth Circuit reversed, with Judge Karen Nelson Moore writing for a panel that also included Judges Siler and Bloomekatz. Applying the Calder v. Jones and Johnson v. Griffin precedents within the circuit's three-part specific-jurisdiction framework, the court held that RHF purposefully directed its allegedly unlawful conduct at Ross in Michigan. The court emphasized that RHF knew as early as 2020 that Ross lived and worked in Michigan, had attempted to mail notice of the default judgment to a Michigan address, and received further confirmation of Ross's Michigan location from a prior garnishment respondent before submitting the summons that reached Detroit Diesel.

The court rejected RHF's argument that Ross's injury did not occur in Michigan because his wages were intercepted before reaching the state. The disbursement checks RHF submitted did not establish that funds were drawn from outside Michigan, and Ross's paystub listed Detroit Diesel at a Detroit address, supporting the inference that wages originated in Michigan. More fundamentally, the court reasoned that Ross's wages were property tethered to Michigan — earned through work in a Michigan factory, regulated by Michigan wage law, and taxed by Michigan — and that RHF's conduct interfered with that property regardless of where funds may have passed in transit.

The court also addressed RHF's contention that it could not have intentionally targeted Michigan because it did not know Ross's exact address when it sent the garnishment summons to Daimler Truck North America LLC, which appears to be the parent of Detroit Diesel. The court was unpersuaded: RHF had admitted learning from AAF that Ross's last-known address was in Michigan, had previously mailed notice to a Michigan address, and had received Penske's garnishment answer confirming Ross was still in Michigan. Because RHF never requested an evidentiary hearing below, its contradicting affidavit was irrelevant to the prima facie analysis.

The panel also resolved the Michigan long-arm statute question the district court had left open, holding that Michigan Compiled Laws section 600.715(2) independently authorized jurisdiction because RHF's out-of-state conduct caused adverse economic consequences to Ross in Michigan. The court drew support from Daniels v. Sommers, 556 P.3d 1113 (Wash. Ct. App. 2024), which it described as one of the few decisions to address whether garnishing a forum-state employee's wages constitutes purposeful availment. In that case, California-based debt collectors who had been assigned a default judgment used it to secure wage-garnishment orders that caused a Washington employer to garnish wages a Washington employee earned there; the Washington Court of Appeals held that the debt collectors had sufficient purposeful contacts with Washington to support personal jurisdiction.

The case is Ross v. Robinson, Hoover & Fudge, PLLC, No. 25-1802 (6th Cir. Apr. 22, 2026), recommended for publication. John A. Evanchek and Curtis C. Warner of Kelley & Evanchek represented Ross; Eugene Xerxes Martin IV of Martin Golden Lyons Watts Morgan PLLC represented RHF.