Law360, New York ( May 21, 2015, 10:40 AM EDT) -- Earlier this month, the New Jersey state appeals court seemingly set a bright-line test balancing the rights of judgment creditors and employees when it comes to monies in a levied bank account. In The Pitney Bowes Bank Inc. v. ABC Caging Fulfillment, 2015 N.J. Super. LEXIS 70 at *1 (App. Div. May 8, 2015), a creditor levied upon a bank account maintained by a business debtor, ABC Caging Fulfillment, at a local community bank, Shore Community Bank. When the judgment creditor, The Pitney Bowes Bank Inc., sought a court order approving the transfer of funds from this account, it received resistance from its judgment debtor. Citing underutilized sections of New Jersey's statutes, ABC argued that the funds in the levied account were completely exempt based upon the fact that the account at issue was a "payroll" account used to pay employees. In response, Pitney Bowes argued that the funds at issue were not exempt because ABC was able to pay its employees through other means. Who was right?...