Kennedy v. Kennedy
This case addresses whether income from a noncompetition agreement is subject to the 65% cap for income executions under CPLR 5241 (g) (1) (ii) in support obligations. Petitioner Nancy E. Kennedy sought to garnish 100% of respondent Kenneth E. Kennedy's noncompetition income from Signet Advertising, Inc., arguing the statutory cap applies only to employer-employee earnings. After initial differing decisions by a Hearing Examiner and Family Court, the Court determined that CPLR 5241, mirroring its federal counterpart, Title III of the Consumer Credit Protection Act, intended the garnishment limitations to apply exclusively to income derived from an employer-employee relationship. The Court concluded that payments for "refraining from rendering personal services" do not constitute "earnings" as commonly defined in legislative contexts. Therefore, the income from the noncompetition agreement is not protected by the CPLR 5241 limitations, leading to the reversal of the Family Court's order and reinstatement of the Hearing Examiner's decision.