Green Belt Bank & Trust v. Van Mill - Garnishment Order Limit Appeal

Iowa Supreme Court

Filed March 6th, 2026

Detected March 6th, 2026

Summary

The Iowa Supreme Court has published its opinion in the case of Green Belt Bank & Trust v. Stephanie Marie Van Mill et al. The appeal concerned the application of Iowa Code section 642.21(1)(e) to limit the amount a judgment creditor could recover through garnishment. The court affirmed the lower court's decision.

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What changed

The Iowa Supreme Court has issued its opinion in Case No. 23-2040, Green Belt Bank & Trust v. Stephanie Marie Van Mill et al. The case involved an appeal by Green Belt Bank & Trust, a judgment creditor, challenging a district court order that limited the amount recoverable through garnishment against Unverferth Manufacturing Company, Inc. The district court had applied Iowa Code section 642.21(1)(e) to cap the recovery, a decision previously affirmed by the Iowa Court of Appeals.

The Supreme Court's opinion, published on March 6, 2026, affirms the lower courts' decisions. This ruling clarifies the application of the garnishment exemption under Iowa Code section 642.21(1)(e) for judgment creditors seeking to recover debts from employers. While this is a specific case outcome, it reinforces existing legal precedent regarding the limits on garnishment orders.

Source document (simplified)

Main Content

Case No. 23-2040

Green Belt Bank & Trust

v.
Stephanie Marie Van Mill, Mashon Michael Van Mill, Rapid Financial Service, LLC a/k/a Small Business Financial Solutions, LLC d/b/a Rapid Finance, Van Mill Farms, LLC, In Rem Judgments, and Unverferth Manufacturing Company, Inc.

Green Belt Bank & Trust (“Green Belt”), a judgment creditor of Mashon Van Mill, appealed the district court’s order of garnishment against Unverferth Manufacturing Company, Inc., which applied Iowa Code section 642.21(1)(e) to limit the amount Green Belt could recover. Green Belt seeks further review of the court of appeals’ decision affirming the order.

County: Butler Trial Court Case No.: EQCV021759

Applicant

Green Belt Bank & Trust

Resister

Stephanie Marie Van Mill, Mashon Michael Van Mill, Rapid Financial Service, LLC a/k/a Small Business Financial Solutions, LLC d/b/a Rapid Finance, Van Mill Farms, LLC, In Rem Judgments, and Unverferth Manufacturing Company, Inc.

Attorney for the Applicant

Jonathan Kramer

Attorney for the Resister

George A. Cady III

Supreme Court

Oral Argument Schedule

15-15-5

Jan 21, 2026 1:30 PM

Briefs

Appellant Brief (200.21 KB)

Appellee Brief (179.47 KB)

Appellant Reply Brief (220.68 KB)

Supreme Court Opinion

Opinion Number:

23-2040

Date Published:

Mar 06, 2026

PDF of the Opinion (146.93 KB)

Court of Appeals

Court of Appeals Opinion

Opinion Number:

23-2040

Date Published:

Mar 05, 2025

Summary

Appeal from the Iowa District Court for Butler County, DeDra Schroeder, Judge. AFFIRMED. Heard by Tabor, C.J., and Schumacher and Chicchelly, JJ. Opinion by Schumacher, J. (10 pages)

Green Belt Bank & Trust, a judgment creditor, appeals an order of garnishment entered by the district court against Unverferth Manufacturing Company, Inc., an employer of judgment debtor Mashon Van Mill. Green Belt challenges the district court’s application of the garnishment exemption under Iowa Code section 642.21(1)(e) (2020) to determine Green Belt could recover “only ten percent of the total invoice value during the garnishment period.” OPINION HOLDS: Upon our review, we affirm.

PDF of the Opinion (104.71 KB)