Carrier411 Services, Inc. v. Insight Technology, Inc., 322 Ga. App. 167

Insight Technology obtained a $1.4 million judgment against Brewer and garnished Carrier411.
Carrier411 answered the garnishment, claiming Brewer was not its employee and no Brewer funds were in its possession.
Insight Technology traversed Carrier411’s answer; Carrier411 moved to dismiss under OCGA § 14-2-1502(a).
Trial court denied the motion to dismiss and granted Insight Technology’s traverse, awarding $736,139.60.
Carrier411 appealed contending: (i) improper dismissal denial, (ii) reverse-piercing the corporate veil, (iii) improper expansion to fraud/collusion with insufficient proof.
Court affirmed, ruling garnishment statute permits continued garnishment and that evidence showed Brewer and Carrier411 colluded to defeat garnishment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Authority to sue in GA	Insight Technology authorized to garnishee Brewer's assets in GA.	Carrier411 defense—Insight Technology lacked certificate of authority; insufficient pleading.	Denial of dismissal affirmed; no proof Insight transacted business in GA.
Reverse-piercing veil	Garnishment reaches Brewer's assets via corporate entities.	Georgia does not recognize reverse-piercing; not applicable here.	Reaffirmed that garnishment action, not reverse-piercing, governs; no error.
Expansion to fraud/collusion claims	Traverse supported by evidence showing fraud/collusion to defeat garnishment.	Claims beyond garnishment scope require more proof to support.	Court acted within garnishment framework; evidence supported findings of fraud/collusion.

Health Horizons v. State Farm Mut. Auto. Ins. Co., 239 Ga. App. 440 (1999) (affirmative defense pleading standards; abatement principles)
A.M. Buckler & Assoc., Inc. v. Sanders, 305 Ga. App. 704 (2010) (garnishment as factbound; evidence sufficiency standard)
Pate v. Pate, 280 Ga. 796 (2006) (garnishment scope under statutory framework)
Gant, Inc. v. Citizens & Southern Nat. Bank, 151 Ga. App. 212 (1979) (garnishment lien unaffected by post-service arrangements)
Stone v. George F. Richardson, Inc., 169 Ga. App. 232 (1983) (independent liability when debtor's property held to defeat garnishment)
W. R. Leasing, Inc. v. Aetna Cas. & Surety, 211 Ga. App. 818 (1994) (trier of fact credibility and evidence weighing in garnishment)
Southern Environmental Group v. Rosebud Landscape Gardeners, 196 Ga. App. 392 (1990) (alter ego considerations in corporate veil discussions)
Acree v. McMahan, 276 Ga. 880 (2003) (reverse-piercing not recognized when adequate remedies exist)
Toporek v. Water Processing Co., 169 Ga. App. 141 (1983) (garnishment to prevent evasions and subterfuges)
Worsham Bros. Co. v. Fed. Deposit Ins. Corp., 167 Ga. App. 163 (1983) (corporate veil shielding debtor; trial court may weigh evidence)