WASHINGTON DEPT. OF SOCIAL & HEALTH SERVICES v. GUARDIANSHIP OF KEFFELER

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Case Basics
Docket No. 
01-1420
Petitioner 
Washington Dept. of Social & Health Services
Respondent 
Guardianship of Keffeler
Advocates
(Argued the cause for the United States, as amicus curiae, supporting the petitioners)
(Argued the cause for the respondents)
(argued the cause for the petitioners)
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Facts of the Case 

The State of Washington, through its Department of Social and Health Services, provides foster care to certain children. It also receives and manages Social Security benefits, which it uses to cover its costs, for many of those children. Such beneficiary children filed suit, alleging that the Department's use of their benefits to reimburse itself for the foster care costs violated the "anti-attachment" provision of Title II of the Social Security Act, which protects certain benefits from "execution, levy, attachment, garnishment, or other legal process." The trial court enjoined the Department from continuing to charge its foster care costs against Social Security benefits and ordered restitution of previous reimbursement transfers. The Washington Supreme Court ultimately affirmed the trial court's holding that the Department's practices violated the anti-attachment provision.

Question 

Does the State of Washington's use of foster childrens' Social Security benefits to reimburse itself for some of its expenditures violate the provision of the Social Security Act that protects benefits from "execution, levy, attachment, garnishment, or other legal process?"

Conclusion 
Decision: 9 votes for Washington Dept. of Social & Health Services, 0 vote(s) against
Legal provision: Social Security, as amended, including Social Security Disability Benefits Reform Act, but excluding Medicare, Medicaid, Supplemental Security Income, and Aid to Families with Dependent Children

No. In a unanimous opinion delivered by Justice David H. Souter, the Court held that the state's use of the Social Security benefits to reimburse itself does not violate the Social Security Act's anti-attachment provision. The Court reasoned that the Department's effort to become a representative payee and its use of Social Security benefits did not amount to employing an "execution, levy, attachment, garnishment, or other legal process" within the meaning of the provision. The Court also noted that a ruing adverse to the state could disadvantage children in foster care.

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WASHINGTON DEPT. OF SOCIAL & HEALTH SERVICES v. GUARDIANSHIP OF KEFFELER. The Oyez Project at IIT Chicago-Kent College of Law. 04 April 2014. <http://www.oyez.org/cases/2000-2009/2002/2002_01_1420>.
WASHINGTON DEPT. OF SOCIAL & HEALTH SERVICES v. GUARDIANSHIP OF KEFFELER, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2002/2002_01_1420 (last visited April 4, 2014).
"WASHINGTON DEPT. OF SOCIAL & HEALTH SERVICES v. GUARDIANSHIP OF KEFFELER," The Oyez Project at IIT Chicago-Kent College of Law, accessed April 4, 2014, http://www.oyez.org/cases/2000-2009/2002/2002_01_1420.