Supreme Court of the United States
Washington State Department of Social and Health Services v. Guardianship Estate of Keffeler
February 25, 2003537 U.S. 371
Summary
Justice Souter delivered the unanimous opinion holding that Washington's use of foster children's Social Security benefits, received as their representative payee, to reimburse itself for current foster-care expenses does not violate 42 U. S. C. § 407(a). The reimbursement practice is not execution, levy, attachment, garnishment, or comparable legal process: the State has no enforceable claim against the children and already holds the benefits under rules permitting their use for current maintenance. The Court deferred to the Commissioner's interpretation permitting reimbursement and rejected the contention that serving a beneficiary's interests necessarily requires maximizing accumulated benefits rather than meeting basic needs. It also rejected the argument that budgeting in anticipation of benefits constitutes a prohibited assignment. The Court reversed and remanded, leaving independent challenges under § 405(j) unresolved. There were no separate opinions.
Holding
- Whether Washington's representative-payee reimbursement practice violates § 407(a)'s prohibition on legal process against Social Security benefits.. The department's appointment as representative payee and reimbursement of current foster-care expenses from benefits in its possession do not violate § 407(a).
- Whether reimbursement for current foster-care maintenance is inconsistent with the regulations or the beneficiary's interests.. The regulations permit the challenged reimbursement for current maintenance, and the beneficiary's interests do not require maximizing accumulated benefits rather than paying ordinary living expenses.
- Whether budgeting in anticipation of Social Security benefits is a prohibited assignment.. The department's budgeting in anticipation of receiving benefits does not constitute an assignment prohibited by § 407(a).
Docket 01-1420
Cited authorities
- 20 C.F.R. § 404.2010
- 20 C.F.R. § 416.601
- 20 C.F.R. § 416.610
- 42 U.S.C. §§ 405
- 20 C.F.R. §§ 404.2021
- 42 U.S.C. §§405
- 42 U.S.C. § 1383(a)(2)(D)(ii)
- 20 C.F.R. §§ 404.2035
Cited by
- (SS) Kaur v. Commissioner of Social Security
- (SS) Mendoza v. Commissioner of Social Security
- (SS) Sweeney v. Commissioner of Social Security
- (SS) Smith v. Commissioner of Social Security
- (SS) Anderson v. Commissioner of Social Security
- (ss)(ps) Bockari v. Commissioner of Social Security
- (ss)(ps) Bockari v. Commissioner of Social Security
- (ss) (consent) Barney v. Commissioner of Social Security