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Mackey v. Lanier Collection Agcy., 486 U.S. 825 (1988)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Mackey v. Lanier Collection Agcy., 486 U.S. 825 (1988)
Mackey v. Lanier Collection Agency & Service, Inc., No. 86-1387 Argued April 19, 1988 Decided June 17, 1988 486 U.S. 825
CERTIORARI TO THE SUPREME COURT OF GEORGIA
Syllabus
After respondent collection agency obtained money judgments against participants in an "employee welfare benefit plan" covered by the Employee Retirement Income Security Act of 1974 (ERISA), its request to garnish the debtors’ plan benefits was granted by a Georgia trial court. The State Court of Appeals reversed, holding that Ga.Code Ann. § 18-4-22.1 (1982), barring the garnishment of "[f]unds or benefits of [an] . . . employee benefit plan or program subject to . . . [ERISA]," exempted plan benefits from garnishment. The Georgia Supreme Court reversed, concluding that § 18-4-22.1 was preempted by ERISA, and that the plan was therefore subject to garnishment under the general state garnishment law.
Held:
1. Section 18-4-22.1, which singles out ERISA employee welfare benefit plans for different treatment than non-ERISA welfare plans under state garnishment procedures, is preempted under § 514(a) of ERISA, which supersedes any state law insofar as it "relate[s] to" ERISA-covered plans. The state statute’s express reference to ERISA plans brings it within the federal law’s preemptive reach. Shaw v. Delta Air Lines, Inc., 463 U.S. 85. Moreover, the possibility that § 18-4-22.1 was enacted to help effectuate ERISA’s underlying purposes is not enough to save it from preemption, since § 514(a) displaces all state laws that fall within its sphere, including those that are consistent with ERISA’s substantive requirements. Metropolitan Life Ins. Co. v. Massachusetts, 471 U.S. 724. Pp. 829-830.
2. Congress did not intend to preempt state law garnishment of an ERISA welfare benefit plan, even where the purpose is to collect judgments against plan participants. Pp. 830-840.
(a) Unlike § 18-4-22.1, Georgia’s general garnishment statute does not single out or specially mention ERISA plans of any kind. The argument that, because the general statute requires plan trustees such as petitioners to respond to garnishment orders with funds otherwise due beneficiary-debtors, and to incur substantial administrative burdens and costs, the statute consequently "relates to" the plan within the meaning of § 514(a) is refuted by certain other ERISA provisions, and by several aspects of that statute’s structure. Although § 502(d) provides that a plan may "sue or be sued" as an entity for specified relief and clearly contemplates the enforcement of money judgments against a plan, and although lawsuits against ERISA plans for run-of-the-mill state law contract or tort claims are relatively commonplace, ERISA does not provide an enforcement mechanism for collecting judgments won in either type of action. In lieu of such a provision, state law collection methods, including garnishment, remain undisturbed by ERISA. See Fed.Rule Civ.Proc. 69(a). Section 514(a)’s language does not support petitioners’ attempt to distinguish, as permissible, garnishment to collect plan creditors’ judgments from, as impermissible, garnishment on behalf of plan participants’ judgment creditors. The fact that § 206(d)(1)’s ban on alienation or assignment is limited to pension benefits also supports the conclusion that Congress did not intend to preclude garnishment of welfare plan benefits. Section 514(a) cannot be read to protect only benefits, but not plans, from garnishment, since § 206(d)(1) demonstrates Congress’ ability to distinguish between benefits and plans when it wished, and since such a construction would render § 206(d)(1) substantially redundant with § 514(a), and therefore superfluous. Pp. 831-838.
(b) Petitioners’ contention that the Retirement Equity Act of 1984 -- which specified that § 514(a)’s preemption provision does not apply to "qualified domestic relations orders" -- establishes that § 514(a), as originally enacted, preempts state attachment and garnishment procedures on the theory that, otherwise, an amendment to save such orders would have been unnecessary, is not persuasive. An equally plausible explanation for the amendment is that Congress meant to clarify the original meaning of § 514(a) by correcting court decisions that had erroneously construed the section as preempting such orders. Even if petitioners’ contention is correct, the opinion of a later Congress as to the meaning of a law enacted 10 years earlier does not control the issue. Rather, ERISA’s language and structure demonstrate the intent of the Congress that originally enacted § 514(a) not to preempt state garnishment procedures. Pp. 838-840.
256 Ga. 499, 350 S.E.2d 439, affirmed.
WHITE, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and BRENNAN, MARSHALL, and STEVENS, JJ., joined. KENNEDY, J., filed a dissenting opinion, in which BLACKMUN, O’CONNOR, and SCALIA, JJ., joined, post, p. 841.
Contents:
Chicago: U.S. Supreme Court, "Syllabus," Mackey v. Lanier Collection Agcy., 486 U.S. 825 (1988) in 486 U.S. 825 486 U.S. 826–486 U.S. 827. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=KGKW4WHKG4X5KTS.
MLA: U.S. Supreme Court. "Syllabus." Mackey v. Lanier Collection Agcy., 486 U.S. 825 (1988), in 486 U.S. 825, pp. 486 U.S. 826–486 U.S. 827. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=KGKW4WHKG4X5KTS.
Harvard: U.S. Supreme Court, 'Syllabus' in Mackey v. Lanier Collection Agcy., 486 U.S. 825 (1988). cited in 1988, 486 U.S. 825, pp.486 U.S. 826–486 U.S. 827. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=KGKW4WHKG4X5KTS.
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