Northern Marianna Islands v. Canadian Imperial Bank of Commerce (Second Circuit)

The Commonwealth of the Northern Mariana Islands sued CIBC to garnish bank accounts held by a delinquent taxpayer at a CIBC subsidiary. Mayer Brown filed an amicus brief on behalf of the Institute of International Bankers arguing that garnishment of a bank account requires service on, and jurisdiction over, the bank holding the account and that New York should not permit garnishment of extra-territorial debts.