Jova Daniels Busby, Inc. v. Greenforest Community Baptist Church, Inc.

Phipps, Judge.

The Georgia Constitution protects all persons from deprivation of property without due process of law. That protection extends to a judgment creditor seeking to enforce its judgment by garnishing a third party holding assets of the debtor. The garnishee here, Green-forest Community Baptist Church, sought relief from a default judgment entered in favor of the garnishor, Jova Daniels Busby, Inc. (JDB). We must determine if the trial court erred by modifying the default judgment without conducting a hearing on the substance of the motion for relief from judgment. Because we find…