United States v. Williams, 2018 WL 3733816 (10th Cir. August 7, 2018) (OK): The panel affirmed the district court’s conclusion that the government may garnish Williams’ bank account for the total amount of restitution because the judgment said it was “due immediately.” Williams argued that according to the schedule of payments, if restitution is not paid immediately, then he had to make payments of 10% of his quarterly earnings. Since he did not pay immediately, the payment schedule went into effect and the government’s application to garnish his bank account was inappropriate. The panel disagreed. The payment schedule was just a way to gather unpaid amounts. Garnishment was appropriate because the judgment said the amount owed was due in full on the date of the judgment. However, before ordering the funds released to the government, the panel instructed the district court to address the bank’s objection to the release of all funds because it had frozen an amount to cover a fraud matter.