Washington State Department of Social and Health Services v. Guardianship Estate of Keffeler

537 U.S. 371, 123 S. Ct. 1017 (2003)

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Washington State Department of Social and Health Services v. Guardianship Estate of Keffeler

United States Supreme Court
537 U.S. 371, 123 S. Ct. 1017 (2003)

  • Written by Liz Nakamura, JD

Facts

The Washington State Department of Social and Health Services (DSHS) (plaintiff) acted as the representative payee for the foster children in its care who were receiving social security benefits, including Old-Age, Survivors, and Disability Insurance (OASDI) and Supplemental Security Income (SSI). OASDI benefits were payable to unmarried children who were dependent on a qualifying elderly or disabled wage earner. SSI benefits were payable to disabled or blind children with less than $2,000 in assets. DSHS deposited the foster children’s social security benefits into Washington’s Foster Care Trust Fund Account (the trust), under which each foster child had an assigned subsidiary account. DSHS would use a foster child’s social security benefits to reimburse itself for funds it provided to the foster parents to cover the foster child’s care and maintenance. If the foster child had living parents, DSHS would seek reimbursement from the living parents first. The Guardianship Estate of Keffeler (Keffeler) (defendant), as part of a class-action lawsuit, sued DSHS, arguing that DSHS’s practice of reimbursing itself for foster-care costs from foster children’s social security benefits violated the Social Security Act’s anti-attachment provision. The Washington Supreme Court ruled in Keffeler’s favor, holding that DSHS’s reimbursement scheme was an impermissible creditor-type assignment of the foster children’s benefits. DSHS appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Souter, J.)

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