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Second Circuit – Federal Debt Collection Procedures Act: United States v. Liounis

Daily Record Staff//June 23, 2026//

Second Circuit – Federal Debt Collection Procedures Act: United States v. Liounis

Daily Record Staff//June 23, 2026//

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United States Court of Appeals for the Second Circuit

Federal Debt Collection Procedures Act — Transferring the action

United States v. Liounis

24-2138

Judges Lynch, Menashi, and Kahn

Background: The debtor moved to transfer a pending garnishment action to the Eastern District of North Carolina where he resides. The court denied the motion and resolved the merits of the action.

Ruling: The Second Circuit vacated. The court held that pursuant to the Federal Debt Collection Procedures Act, if the debtor so requests, the action shall be transferred to the district court for the district in which the debtor resides. It is a mandatory request. Failure to do so is not subject to harmless error review.

Peter Liounis, pro se; Varuni Nelson, United States attorney, for the appellee.

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