Brindle v. Arata, 940 N.E.2d 320

On June 4, 2009 Brindle and Arata entered an agreed judgment in Arata's favor for legal services.
On March 11, 2010 Arata commenced a supplemental proceeding and served garnishment interrogatories on National City Bank where Brindle held a deposit account.
On March 22, 2010 National City reported Brindle had $3,367.01 in the account when interrogatories were filed.
On March 17, 2010 Brindle filed an exemption claim and requested a hearing, introducing a voucher for a $3,268 check from the Academy of Art University.
Brindle testified she received a student loan paid directly to the University, with funds deposited into her account (March 1, 2010) amounting to about $3,271.
On March 26, 2010 the trial court denied Brindle's exemption claim in part, ordering National City Bank to remit funds to the clerk of courts while preserving $300.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do student loan funds retain exempt status when deposited in a personal account?	Arata argues deposit defeats exemption.	Brindle argues exemption persists despite deposit.	Exemption remains; funds retain status despite deposit.
Is there a termination of exemption by depositing funds into a personal account under federal law?	Exemption can be defeated by disposition.	No termination mechanism shown.	Plain-language exemption applies; deposit does not terminate.
Is Brosamer v. Mark applicable to this student loan exemption issue?	Arata relies on Brosamer to limit exemption.	Brindle argues Brosamer not controlling here.	Brosamer is inapplicable; not controlling.

Indiana Bureau of Motor Vehicles v. Orange, 889 N.E.2d 388 (Ind.Ct.App.2008) (statutory interpretation governs exemptions and their scope)
Brosamer v. Mark, 561 N.E.2d 767 (Ind.1990) (ERISA anti-alienation provisions do not map to student loan exemptions)