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United States v. Ashcraft

United States Court of Appeals for the Eighth Circuit

732 F.3d 860 (2013)

Facts

For some period of time before 2004, Joyce Ashcraft (defendant) worked for Amana Refrigeration. Amana provided its employees with long-term disability insurance through Principal Life Insurance Company (PLIC). After Ashcraft’s employment aggravated an existing medical condition, Ashcraft became unable to work, and she began receiving long-term disability payments from PLIC. The payments were scheduled to continue until 2016, when Ashcraft turned 65. In 2004, Ashcraft pleaded guilty to various criminal charges and was sentenced to imprisonment and restitution. In February 2012, the United States government (plaintiff) sought to garnish Ashcraft’s disability payments as part of Ashcraft’s restitution sentence. Ashcraft objected to the proposed garnishment based on the Consumer Credit Protection Act, which limits the garnishment of earnings. Ashcraft contended that her disability payments constituted earnings for purposes of the statute. The district court overruled Ashcraft’s objection, and Ashcraft appealed to the United States Court of Appeals for the Eighth Circuit.

Rule of Law

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Issue

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Holding and Reasoning (Melloy, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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