Lockhart v. United States

PETITIONER: James Lockhart
RESPONDENT: United States et al.
LOCATION: United States Court of Appeals for the Ninth Circuit

DOCKET NO.: 04-881
DECIDED BY: Roberts Court (2005-2006)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 546 US 142 (2005)
GRANTED: Apr 25, 2005
ARGUED: Nov 02, 2005
DECIDED: Dec 07, 2005

ADVOCATES:
Brian Wolfman - argued the cause for Petitioner
Lisa Schiavo Blatt -
Lisa S. Blatt - argued the cause for Respondents

Facts of the case

In 2002 the U.S. began withholding a portion of Lockhart's Social Security payments to offset his debt on federally reinsured student loans that were more than 10 years overdue. Lockhart sued, arguing the offset was barred by the 10-year statute of limitations of the Debt Collection Act (1982). The district court dismissed Lockhart's suit, and the Ninth Circuit affirmed.

Question

Could the United States offset Social Security benefits to collect a student loan debt that had been outstanding for over 10 years?

Media for Lockhart v. United States

Audio Transcription for Oral Argument - November 02, 2005 in Lockhart v. United States

Audio Transcription for Opinion Announcement - December 07, 2005 in Lockhart v. United States

John G. Roberts, Jr.:

Justice O’Connor has the opinion in No. 04-881, Lockhart versus United States.

Sandra Day O'Connor:

This case comes to us on writ of certiorari to the Court of Appeals for the 9th Circuit.

It concerns the Government’s effort to withhold part of the petitioner’s Social Security benefits to offset his debt on federally reinsured student loans that are more than ten years overdue.

Whether the Government can do this is determined by a rather complicated interplay of four statutes.

First, we have two statutes about time limits.

The Debt Collection Act lets the Government collect debts by administrative offsets, subject to a general ten-year statute of limitations; but the Higher Education Technical Amendments of 1991 eliminate time limits on suits to collect student loans.

Next, we have two statutes about the Government’s ability to subject Social Security benefits to offset.

Social Security benefits are generally exempt from attachment or other legal process.

The Social Security Act purports to protect this anti-attachment rule with an express reference provision.

The statute says no other provision of law may be construed to modify this section except to the extent that it does so by express reference.

But the Debt Collection Improvement Act of 1996 subjects Social Security benefits to administrative offset, making express reference to the Social Security Act.

Now, petitioner here argued that the Debt Collection Act’s ten-year statute of limitations controlled, so the Government could not offset his Social Security benefits.

The 9th Circuit disagreed and held that the Higher Education Technical Amendments had eliminated that time limit as to student loans.

In an opinion filed today with the Clerk of the Court, we affirm the 9th Circuit’s judgment.

We hold that the 1991 and 1996 statutes make Social Security benefits subject to offset, providing exactly the sort of express reference the Social Security Act says is necessary to supersede the anti-attachment provision and remove the ten-year limit that we otherwise would say barred the Government’s action.

Debt collection by Social-Security offset was not authorized until 1996, five years after the abrogation of time limits; but the plain meaning of the Higher Education Technical Amendments must be given effect, even though Congress may not have foreseen all of its consequences.

We do not decide whether the Social Security Act’s express reference provision is valid.

Justice Scalia has filed a concurring opinion.