Ernest Bankas (defendant) pleaded guilty to fraudulently obtaining student loans while earning three master’s degrees, a doctorate, and a law degree. The court sentenced him to two years in prison and ordered him to pay $340,810 in restitution to the U.S. Department of Education under the Mandatory Victims Restitution Act. After his release, the court garnished royalty income Bankas earned from a book. Four years later, the government found Bankas working as a health aide for at least $630 every two weeks and garnished that income as well. Bankas objected and filed a form requesting a hearing on financial hardship grounds, claiming child support and child-care exemptions for his five children—who were already over eighteen. The judge denied a hearing but held a telephone status conference and told Bankas he could not exempt those expenses and that no exemption exists for financial hardship alone. Bankas appealed, arguing that denying a hearing violated due process and that the garnishment calculations improperly reflected fluctuations in his pay, which increased just before garnishment began.