Lockhart v. United States — Scalia, J., Concurring

Summary

Justice Scalia concurs in the judgment, agreeing that subsequent legislation authorized the collection of student-loan debt by administrative offset despite the Social Security Act's express-reference requirement. He argues that a prior legislature cannot bind a succeeding one with such requirements, as subsequent statutes can impliedly repeal them without explicit reference. His opinion clarifies the relationship between express-reference provisions and implied repeals.