In Lange v. CIR Law Offices, 2010 WL 2524089 (S.D.Cal. 2010) Judge Bencivengo found that a law firm engaged in debt collection whose post-judgment garnishment had erroneously garnished exempt social security funds did not violate the FDCPA.  Judge Bencivengo explained: 


In the absence of any evidence that CIR had any knowledge of the nature of Lange’s account prior to the notice of levy, this Court finds that CIR followed proper collection procedures pursuant to California law to collect on a valid judgment. Due to the Credit Union’s failure to comply with the provisions of California Code of Civil Procedure § 704.080(e), there was an erroneous garnishment of Lange’s exempt social security funds. The funds were returned to the plaintiff when evidence of their exempt status was provided. Under these undisputed facts, the garnishment of Lange’s exempt funds cannot constitute an unfair and unconscionable means of collecting a debt by CIR and therefore CIR did not violate FDCPA or the Rosenthal Act.