In an opinion released On October 1, 2015, the Court of Special Appeals in Morgan Stanley & Co., Inv. v. Andrews held that the mere fact that money was placed into a joint back account would not necessarily allow a judgment creditor of only one of the parties to successfully garnish the account. In Morgan Stanley the father created a joint account with his son in which only the father deposited funds for the purpose of allowing the son to supervise and pay bills relating to the vacation property of the father. The son did not deposit any money into the account nor did the son pay any of his bills out of the joint bank account. The Court of Special Appeals held that there was a rebuttable presumption that joint account holders’ funds may be garnished if a creditor has a judgment against only one account holder, but that the presumption can be rebutted by clear and convincing evidence if only the one person contributed proceeds to the account and only the same party owned the proceeds in the account. In Morgan Stanley only the father deposited money to the account and the placing of the son on the account was solely to allow the son to pay the father’s bills. Accordingly, in a case of first impression, the Court of Special Appeals held that the father had successfully rebutted the presumption by clear and convincing evidence that the proceeds in the account were solely the property of the father and that a judgment only against his son was not an appropriate basis to attach the bank account.