In Hrachova v. Cook, Civil No. 5:09-cv-00095-PRL (M.D. Fla. May 29, 2026), the Middle District of Florida addressed post-judgment collection efforts arising from a long-running Form I-864 enforcement case.
The plaintiff, Iryna Hrachova, had sued Denver Cook for damages and specific performance of a Form I-864 Affidavit of Support. After a non-jury (“bench”) trial, the court entered judgment in her favor for past support and ordered Mr. Cook to continue supporting her at 125 percent of the Federal Poverty Guidelines until the I-864 obligation terminated by law.
The most recent 2026 decision did not decide whether the I-864 was enforceable. That issue had already been decided. Instead, the case concerned Ms. Hrachova’s efforts to collect on the judgment, which she claimed had grown to more than $180,000 with additional support and interest.
The court addressed two collection targets: Mr. Cook’s IRA account held with Empower Retirement and a Truist Bank account containing protected federal benefits. The court rejected Ms. Hrachova’s effort to garnish the IRA funds and denied her effort to reach the protected bank-account funds.
Why This Decision Matters
1. The case shows that I-864 enforcement can include specific performance and long-term collection activity.
One useful feature of the decision is its procedural history. The court described the original action as one for “specific performance of an Affidavit of Support, Form I-864.” That matters because I-864 litigation is not always just about a single damages award. In many cases, the sponsored immigrant may obtain a judgment for past-due support and an order requiring ongoing support until the statutory obligation terminates.
Notably, the plaintiff succeeded not only for herself, but also on behalf of a minor child. That is a useful reminder that I-864 enforcement may involve derivative or household-related issues, depending on how the case was pleaded and litigated.
For sponsored immigrants, the broader lesson is straightforward: a Form I-864 judgment may be enforceable, but collecting on that judgment can become its own separate battle.
2. The bankruptcy treatment of an I-864 debt does not necessarily control later collection remedies.
The most important issue in the decision is the court’s treatment of the earlier bankruptcy ruling.
Ms. Hrachova argued that because Mr. Cook’s I-864 judgment had previously been treated as a nondischargeable “domestic support obligation” in bankruptcy, she should be able to garnish his IRA funds. (That ruling, obtained earlier in this case history, is a majorly important ruling that I continue to cite today). The plaintiff’s argument here was a serious argument. In bankruptcy, domestic support obligations receive special treatment, and certain exemptions may not protect assets from collection of those obligations.
But the district court rejected the argument outside the bankruptcy context. Even though the bankruptcy court had previously held the I-864 judgment to be a nondischargeable domestic support obligation, the district court did not treat the same debt as alimony or child support for purposes of the collection exemption applicable to retirement funds.
That distinction matters. The court treated the bankruptcy ruling as limited to bankruptcy. It reasoned that the bankruptcy code provisions relied on by Ms. Hrachova applied in bankruptcy cases, not in this later non-bankruptcy garnishment proceeding.
This is a mixed and important result for I-864 plaintiffs. On one hand, I-864 judgments may be powerful enough to survive bankruptcy discharge. On the other hand, that does not automatically mean the judgment receives every collection advantage available to traditional alimony or child-support creditors under state or federal collection law.
3. The court emphasized that Form I-864 support is separate from state-law alimony and child support.
The central unfavorable holding for the sponsored immigrant was the court’s conclusion that the federal I-864 judgment was not itself child support or alimony for purposes of reaching otherwise exempt retirement funds.
The court acknowledged the familiar principle that a Form I-864 obligation is a federal obligation separate from state-law support rights. That principle often helps sponsored immigrants. For example, it means a divorce decree or family-law settlement generally cannot erase the federal I-864 obligation.
But here, the same principle cut the other way.
Because the I-864 obligation was separate from state-law child support and alimony, the court refused to treat the judgment as child support or alimony for purposes of garnishing exempt IRA funds. In other words, the plaintiff could not use the federal nature of the I-864 obligation to avoid divorce-law defenses, while also treating the same obligation as state-law alimony or child support for purposes of collection remedies.
For I-864 plaintiffs, the case shows that “the I-864 is support” is not always enough. The relevant question may be: support for what legal purpose? Bankruptcy discharge? Divorce defenses? Garnishment exemptions? Federal benefits? Each context may have its own rules.
4. The decision also limited garnishment of protected federal benefits.
The court reached a similar conclusion as to the Truist Bank account.
Ms. Hrachova argued that she should be able to garnish otherwise exempt Social Security disability benefits to collect the I-864 judgment. She relied in part on 8 U.S.C. § 1183a(c), which incorporates certain federal debt-collection remedies, including garnishment.
The court rejected the argument. It reasoned that, although federal law may allow Social Security benefits to be garnished for child support and alimony, the I-864 obligation was distinct from child support and alimony. The bank’s protected-amount determination under the federal benefit-protection regulations was therefore conclusive. A sponsored immigrant may have a valid and substantial I-864 judgment, but protected federal benefits may still be shielded from garnishment unless a specific exception applies.
Practical Takeaways
- An I-864 plaintiff can win the merits and still face a difficult collection process.
- A judgment enforcing Form I-864 may survive bankruptcy discharge, but that does not automatically make it equivalent to alimony or child support for every later collection purpose.
- The legal characterization of I-864 support is context-specific. The same “federal obligation separate from family law” principle can help plaintiffs in one setting and hurt them in another.
- Retirement funds may be protected by state exemption law even when the underlying judgment arises from Form I-864 support.
- Social Security disability benefits and other protected federal benefits may remain difficult or impossible to garnish unless the creditor fits within a recognized statutory exception.
- Plaintiffs should think about collectability early. Winning an I-864 judgment is only part of the problem; identifying reachable assets may be just as important.
- The decision is useful for sponsors resisting collection from exempt assets, but it also gives I-864 plaintiffs a roadmap for anticipating and briefing these issues more carefully.
Limits and Cautions
This decision is a federal trial-court order from the Middle District of Florida. It is not binding nationwide.
The ruling also depends heavily on the procedural posture. The case was not about whether the Form I-864 was enforceable. That had already been decided. The issue was whether the plaintiff could use garnishment to reach specific categories of assets after judgment.
The decision is also mixed. It confirms the enforceability and long-term consequences of an I-864 judgment, but the key collection holdings are pro-sponsor. The court protected the IRA funds and the federal-benefit account from garnishment.
Finally, the decision should not be overread. It does not mean I-864 judgments are weak. It means that collection remedies still depend on the specific asset, the governing exemption law, and the procedural context. For lawyers representing sponsored immigrants, the lesson is not to abandon collection efforts, but to identify assets and exemption issues early.
