The proceeds of an insurance policy payable to the defendant, a non-resident, were attached by garnishment. The defendant, who was served by publication, filed a paper entitled "Special Appearance" to question the jurisdiction of the court over his person and property. The lower court sustained the special appearance on the ground that the proceeds of the policy were exempt from garnishment. Held, that the exemption of the proceeds was not material to the question of jurisdiction in rem, so it should not have been considered on special appearance. Reversed with leave to the defendant to enter a general appearance. Scott v. Wamsley, (Iowa 1932) 245 N. W. 214.

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