Supreme Court of the United States

Lockhart v. United States

December 7, 2005546 U.S. 142

Summary

Justice O'Connor, writing for a unanimous Court, held that the Government may offset Social Security benefits to collect qualifying student-loan debts outstanding for more than ten years. The 1996 Debt Collection Improvement Act expressly authorized Social Security offsets, and the 1991 Higher Education Technical Amendments eliminated the otherwise applicable time limit for student-loan collection. Retention of the general ten-year bar in the 1996 legislation did not displace that student-loan exception. Justice Scalia joined the Court's opinion and separately argued that an earlier Congress cannot bind a later Congress through an express-reference requirement; no other Justice joined his concurrence.

Holding

  • Whether qualifying student-loan debts outstanding for more than ten years may be collected by offsetting Social Security benefits.. The Government may collect those debts through offsets against Social Security benefits.
  • Whether the Social Security Act's express-reference requirement bars the offsets.. The Debt Collection Improvement Act expressly references the Social Security Act's anti-attachment provision and satisfies its express-reference requirement; the Court need not decide whether that requirement otherwise binds subsequent legislation.

Docket 04-881

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