Law Offices of David Efron, PC v. Candelario, No. 16-1010 (1st Cir. 2016)Annotate this Case
David Efron and Madeleine Candelario were involved in a divorce proceeding and a pending marital property division proceeding before the superior court of Puerto Rico. In the divorce proceeding, the superior court ordered Efron, the sole owner of the Law Offices of David Efron, P.C. (the Efron Firm), to pay almost $5.5 million plus interest to Candelario. When Efron refused to pay, Candelario resorted to garnishing funds owned by Efron. In a separate case, the Efron Firm secured a settlement for its clients, and the defendants deposited the Efron Firm’s attorney’s fees in the federal district court registry. In the meantime, in the divorce proceeding, the court issued an order garnishing amounts owed to Efron. Candelario requested that the district court transfer the amounts deposited in the district court registry pursuant to the settlement in the separate case. The superior court granted the request. The First Circuit reversed, holding that funds in the federal court registries are protected under the doctrine of custodia legis from garnishment or attachment by a state court. Remanded.