Lockhart v. United States, 546 U.S. 142 (2005)
Primary Holding
The Supreme Court held that the United States may offset Social Security benefits to collect student loan debts that are over 10 years old, as the Debt Collection Improvement Act allows for such offsets despite the protections generally afforded to Social Security benefits under the Social Security Act.
In the case of Lockhart v. United States, the Supreme Court decided that the government can take money from Social Security benefits to pay off student loan debts that are over 10 years old. This is important because it shows that even if a debt is old, the government can still collect it by offsetting your Social Security payments. Consumers should be aware that if they have old student loans, their Social Security benefits could be affected, especially if they haven't made payments for a long time.
AI-generated plain-language summary to help you understand this case
In Lockhart v. United States, 546 U.S. 142 (2005), the petitioner, James Lockhart, had incurred federally reinsured student loans between 1984 and 1989 under the Guaranteed Student Loan Program. After failing to repay these loans, which were eventually reassigned to the Department of Education, Lockhart's debt was certified to the Department of the Treasury. In 2002, the government began offsetting a portion of Lockhart's Social Security benefits to collect on this debt, some of which was over 10 years delinquent. Lockhart contested the offset in Federal District Court, arguing that the Debt Collection Act’s 10-year statute of limitations rendered the offset time-barred. The District Court dismissed his complaint, and this decision was affirmed by the Court of Appeals for the Ninth Circuit. Lockhart subsequently sought certiorari from the Supreme Court to resolve a conflict between the Ninth Circuit's ruling and a similar case decided by the Eighth Circuit. The background context of the case involves the Debt Collection Act of 1982, which allows for the collection of debts through administrative offsets, but generally prohibits offsets against Social Security benefits due to protections in the Social Security Act. However, amendments to the Debt Collection Act in 1996 allowed for such offsets under specific conditions. The case ultimately centered on whether the government could offset Lockhart's Social Security benefits despite the age of the debt and the protections afforded by the Social Security Act.
Whether the United States may offset Social Security benefits to collect a student loan debt that has been outstanding for over 10 years.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- November 2, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Central Va. Community College v. Katz, 546 U.S. 356 (2006)
Consumer WonCongress has the authority to abrogate state sovereign immunity in bankruptcy proceedings, allowing a bankruptcy trustee to pursue actions against state agencies to recover preferential transfers made by a debtor.
EC Term of Years Trust v. United States, 550 U.S. 429 (2007)
Consumer LostA trust cannot challenge an IRS levy on its property through a tax refund action if it has missed the statutory filing deadline for contesting the levy under 26 U.S.C. §7426(a)(1).
Logan v. United States, 552 U.S. 23 (2007)
Consumer LostThe "civil rights restored" exemption in 18 U.S.C. §921(a)(20) does not apply to state-court convictions that did not result in a loss of civil rights, meaning that offenders who retained their civil rights at all times are not eligible for relief from the consequences of their convictions under this provision.
Will v. Hallock, 546 U.S. 345 (2006)
Consumer LostThe refusal to apply the judgment bar of the Federal Tort Claims Act is not subject to collateral appeal, as it does not constitute a final decision under 28 U.S.C. §1291.