The decision in Umbro is probably not the last word on the subject of garnishing domain names. The Virginia court relied on cases involving the garnishment of telephone numbers, which the court thought were analogous to domain names. Some courts have held that telephone numbers can not be garnished, while other courts have allowed garnishment. Perhaps NSI opposed the garnishment in Umbro because it is attempting to avoid the administrative burden of compliance with garnishment orders. NSI may want to rethink its position.
Similar cases are sure to recur, and contrary results are likely.
NSI would then need to keep track of the jurisdictions in which garnishment is and is not allowed. Simply complying with all garnishment orders wherever issued seems much easier.