Bennett v. Arkansas, 485 U.S. 395 (1988)

Bennett v. Arkansas

No. 86-6124

Argued March 2, 1988
Decided March 29, 1988
485 U.S. 395

CERTIORARI TO THE SUPREME COURT OF ARKANSAS

Syllabus

Relying on an Arkansas statute authorizing the State to seize a prisoner’s property, including his Social Security benefits, in order to help defray the cost of maintaining its prison system, Arkansas filed suit in state court to attach petitioner’s Social Security benefits. The trial court directed that a portion of petitioner’s benefits be seized, rejecting his argument that the state law violates the Supremacy Clause of the Federal Constitution because it permits the State to attach funds that are exempt from legal process under 42 U.S.C. § 407(a). The Supreme Court of Arkansas affirmed, holding that there is no conflict between the state and federal statutes because § 407(a) contains an "implied exception to exemption from legal process" when a State provides for a Social Security recipient’s care and maintenance.

Held: The Arkansas statute violates the Supremacy Clause. There is no "implied exception" to the express language of § 407(a) and its clear intent that Social Security benefits not be attachable, even though the State provides for all of petitioner’s needs. The State is not a statutorily intended beneficiary of petitioner’s Social Security benefits. Rose v. Rose, 481 U.S. 619, distinguished.

290 Ark. 47, 716 S.W.2d 755, reversed.