MEYER, Justice.
This case presents the question of whether Minn.Stat. § 575.05 (2010) authorizes a district court to issue a temporary injunction prohibiting a judgment debtor from transferring or disposing of property that is not presently in the hands of or due to the judgment debtor. The property at issue in this case is the interest of respondent Andrew C. Grossman, the judgment debtor, in a spendthrift trust. The district court issued a temporary injunction prohibiting Grossman from disposing of any money or property he has received, is due to receive, or will receive from the trust. The court of appeals reversed. We conclude that, based on its plain language, Minn.Stat. § 575.05 authorizes a district court to enjoin the disposition of a judgment debtor's property only if that property is in the hands of the judgment debtor, in the hands of a third party, or due to the judgment debtor at the time the district court issues its order. Because the judgment creditor, appellant Fannie Mae, does not argue that Grossman's interest in this trust is Grossman's property that is currently in the hands of Grossman or a third party or currently due to Grossman, the requirements of Minn.Stat. § 575.05 are not met. We therefore affirm the court of appeals.
In 2007 an Oklahoma district court entered judgment against Andrew Grossman in favor of Fannie Mae to collect on a commercial mortgage loan. Including accrual of post-judgment interest, the unpaid balance of the judgment is now more than $8 million. Fannie Mae docketed the judgment in Hennepin County District Court and pursued collection.
Fannie Mae conducted discovery related to Grossman's assets. See Minn.Stat. § 575.02 (2010) (authorizing examination of
Grossman's father died in January of 2010.
In February 2010 Fannie Mae filed an ex parte motion for a temporary restraining order to prohibit the transfer or disposition of any interest Grossman had in his father's estate. While its request was broadly worded to apply to any interest in Grossman's father's estate, the only specific interest in the estate of Grossman's father that Fannie Mae referenced was Grossman's interest in trust proceeds. In support of the temporary restraining order, Fannie Mae presented evidence to the district court that Grossman had transferred assets out of the country and beyond the reach of Fannie Mae. Fannie Mae relied on Minn.Stat. § 575.05 as authority for the order.
The district court granted Fannie Mae's ex parte motion for a temporary restraining order. After briefing and argument, the court converted the temporary restraining order into a temporary injunction on June 2, 2010. The district court based its authority to issue the temporary injunction on Minn.Stat. § 575.05. The temporary injunction stated:
There is no evidence in the record that Grossman had received any money or assets from the trust as of the date of the temporary injunction.
Grossman appealed the district court order granting the temporary injunction.
We review a district court's decision to issue a temporary injunction for an abuse of discretion. Carl Bolander & Sons Co. v. City of Minneapolis, 502 N.W.2d 203, 209 (Minn.1993). A district court abuses its discretion when it bases its conclusions on an erroneous interpretation of the applicable law. State v. Askland, 784 N.W.2d 60, 62 (Minn.2010). In addition, the interpretation of a statute is a legal issue that we review de novo. See State v. Leathers, 799 N.W.2d 606, 608 (Minn.2011).
When interpreting a statute, the role of the court is to "ascertain and effectuate the intention of the legislature." Minn.Stat. § 645.16 (2010). In construing the language of a statute, we give words and phrases their plain and ordinary meaning. Amaral v. St. Cloud Hosp., 598 N.W.2d 379, 384 (Minn.1999). If the language of a statute is plain and unambiguous, it is presumed to manifest legislative intent and a court must give it effect. Burkstrand v. Burkstrand, 632 N.W.2d 206, 210 (Minn.2001).
The district court issued a temporary injunction prohibiting Grossman from transferring or disposing of certain assets pursuant to Minn.Stat. § 575.05. As a result, we begin by looking at the language of section 575.05. It states, in relevant part:
Minn.Stat. § 575.05 (emphasis added).
Under the plain language of section 575.05, a district court may order the following categories of a judgment debtor's property to be applied toward the satisfaction of a judgment: (1) property in the hands of the judgment debtor; (2) property in the hands of another person; and (3) property due to the judgment debtor. The district court can also forbid the transfer or other disposition of the debtor's unexempt property. Id. Although the statute does not expressly define what unexempt property may not be transferred or disposed of, that property is limited to the three categories of property defined in the first sentence—property in the hands of the judgment debtor, the judgment debtor's property in someone else's hands, and property due to the judgment debtor. See State v. Gaiovnik, 794 N.W.2d 643, 647 (Minn.2011) ("When interpreting statutes, we do not examine different provisions in isolation. Instead, we construe a statute `as a whole,' and `[w]ords and sentences are understood ... in the light of their context.'" (quoting Christensen v. Hennepin Transp. Co., 215 Minn. 394, 409, 10 N.W.2d 406, 415 (1943))).
While the district court temporarily enjoined Grossman from disposing of any money or other assets he received because of his father's death, the only specific asset
Instead, Fannie Mae argues that in the future, Grossman's interest in the trust proceeds will become his property or will be due to him.
We reject Fannie Mae's argument. Fannie Mae is asking us to read language into Minn.Stat. § 575.05 when it contends that the statute permits a district court to issue an anticipatory order enjoining a judgment debtor's conduct in the future if and when property is received by or becomes due to the debtor. The plain language of Minn.Stat. § 575.05 does not authorize a district court to issue an anticipatory order that forbids a judgment debtor from disposing of property that is not in the hands of or due to the judgment debtor at the time the order is issued. The statute does not use language referring to property that the debtor will possess or that will become due to the debtor in the future. We "will not read into a statute a provision that the legislature has omitted, either purposely or inadvertently." Reiter v. Kiffmeyer, 721 N.W.2d 908, 911 (Minn.2006).
This conclusion is consistent with our decision in Knott v. Hawley, 166 Minn. 363, 364, 207 N.W. 736, 736 (1926), which involved a receiver appointed to collect a judgment debtor's future earnings to apply to the plaintiff's judgment under a predecessor of Minn.Stat. § 575.05. See Gen. Stat.1923, § 9453. At the time, another statutory provision allowed for the garnishment and attachment of salary or wages, but it only applied to compensation earned. Knott, 166 Minn. at 364, 207 N.W. at 736 (citing Gen.Stat.1923, § 9364). We ruled that there was no authority for "impound[ing] compensation which is to result in the future from [the judgment debtor's]
The district court's order is analogous to the order appointing a receiver to collect future earnings in Knott. Without statutory authority, the district court enjoined Grossman in advance from disposing of assets he may receive in the future from the trust. The district court's order applied to property the judgment debtor may possess or that may become due to him in the future without requiring the judgment creditor to show that such property was currently in the hands of the judgment debtor or currently due to the judgment debtor, as required by Minn.Stat. § 575.05.
Finally, Fannie Mae argues that the district court was authorized to prospectively enjoin Grossman from disposing of property even if he has not yet received that property because section 575.05 applies to any interests or claims that belong to a debtor, whether certain or contingent. In support, Fannie Mae relies on Lange v. Fidelity & Casualty Co., 290 Minn. 61, 185 N.W.2d 881 (1971). Fannie Mae's reliance on Lange is misplaced.
In Lange, a creditor sought the appointment of a receiver in proceedings supplementary to execution of a monetary judgment against the debtor. 290 Minn. at 64, 185 N.W.2d at 884. The judgment debtor was insolvent but had a potentially actionable claim for bad faith failure to negotiate against his insurer that he refused to pursue. Id. at 64, 185 N.W.2d at 884. We ruled the appointment of a receiver to pursue the bad-faith cause of action against the insurer was authorized by Minn.Stat. § 575.05. Id. at 69-70, 185 N.W.2d at 887. We reasoned that "receivers are regularly appointed to collect assets due a judgment debtor" and that assets of a debtor "often ... include unliquidated tort and breach-of-contract claims." Id. at 69, 185 N.W.2d at 887 (emphasis added). In Lange we concluded that the unliquidated claim of the judgment debtor against his insurer was property "due" the judgment debtor and, therefore, the district court's order was expressly permitted by the language of section 575.05. For this reason, we do not read Lange as support for a temporary injunction that prohibits a judgment debtor from disposing of assets that will be due to the judgment debtor in the future.
In conclusion, we hold that the district court abused its discretion when it issued the temporary injunction. Fannie Mae does not contend that the trust proceeds constitute Grossman's property that is currently in the hands of Grossman or a third party, or that it is property currently due to Grossman. As a result, the district court's temporary injunction was not authorized by Minn.Stat. § 575.05. Because the district court lacked the authority to issue the temporary injunction, we need not address whether the temporary injunction violated the law on spendthrift trusts.
Affirmed.