the garnishee but are still subject to a contingency that has not occurred and thus has not assuredly made the money the debtor’s own.” Id. at 1356 n. 34; see also Cummings Gen, Tire Co. v. Volpe Constr. Co., 230 A.2d 712, 713 (D.C.1967) (“[M]oney payable upon a contingency or condition is not subject to garnishment until the contingency has happened or the condition has been fulfilled”). Accordingly, the District of Columbia Court of Appeals has long held that future rental payment to be owed by a tenant constitutes a “contingent liability” at the time that a writ of garnishment is levied, and therefore, is not considered a “credit” that may be attached by a judg ment creditor under Section 16-546. United States Fidelity & Guar. Co. v. Wrenn, 67 App.D.C. 94, 89 F.2d 838, 840-41 (1937) (<HOLDING>); see also Smith, 644 A.2d at 1356 n. 34
holding that back rent is debt under the fdcpa holding lessor entitled to full months rent when rent due on first of month and lease rejected on second holding that unearned rent is not a debt  and instead constitutes a contingent liability because rent does not accrue to the lessor as a debt unless the lessee has enjoyed the use of the land holding that future rent is not attachable under statute providing that a debt is not attachable unless it is certain to become due holding that effect of discharge of debt under bankruptcy code is the same as it was under the 1898 bankruptcy act it is not an extinguishment of the debt but only a bar to enforcement of the debt as a personal obligation of the debt or