Commonwealth Ex Rel. Morris v. Morris

984 S.W.2d 840, 1998 Ky. LEXIS 138, 1998 WL 741804
CourtKentucky Supreme Court
DecidedOctober 15, 1998
Docket96-SC-790-DG
StatusPublished
Cited by13 cases

This text of 984 S.W.2d 840 (Commonwealth Ex Rel. Morris v. Morris) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth Ex Rel. Morris v. Morris, 984 S.W.2d 840, 1998 Ky. LEXIS 138, 1998 WL 741804 (Ky. 1998).

Opinions

LAMBERT, Chief Justice.

This Court granted discretionary review (CR 76.20) to decide whether KRS 403.212(2)(b), a statute that mandates inclusion of Supplemental Security Income (“SSI”) benefits in the income computation for calculation of child support payments, is in conflict with 42 U.S.C. § 407(a), an anti-attachment statute relating to SSI benefits. If KRS 403.212(2)(b) indeed conflicts with the federal statute, then the SSI provision of the state statute must yield by virtue of the Supremacy Clause of the United States Constitution. U.S. CONST, art. VI, § 2.

BACKGROUND

Pursuant to a divorce decree entered on May 19, 1993, Eddie Morris, appellee, was ordered by the Wayne Circuit Court to pay support in the amount of $31.50 per week for his four minor children. On December 22, 1993, Morris was awarded SSI benefits upon a finding that he was disabled. He filed his first motion to reduce child support on March 7, 1994, claiming that SSI was specifically excluded from a determination of a parent’s income for child support purposes. At that time, KRS 403.212 excluded SSI benefits from the child support calculation. On March 15, 1994, the court ordered Morris to pay $200.00 in child support arrearage. An agreed judgment and order was entered on August 16, 1994, which required Morris to pay $31.50 a week in child support and $29.90 a month in child support arrearage.

On December 2, 1994, Moms filed a second motion to reduce child support, and on January 19, 1995, the court denied his motion, citing the amendment of KRS 403.212, effective July 15, 1994, which specifically required consideration of SSI benefits in making a determination of parental income for child support purposes.

Morris appealed from the order of the Wayne Circuit Court to the Kentucky Court of Appeals, and on June 7,1996, a unanimous panel of that court reversed the judgment of the trial court, holding KRS 403.212(2)(b) to [841]*841be in conflict with 42 U.S.C. § 407(a) in violation of the Supremacy Clause of the United States Constitution.

THE STATUTES: 42 U.S.C. 407(a) and KRS 403.212(2) (b)

The Supplemental Security Income program provides benefits to those who are blind, disabled, or 65 or older, and who are otherwise eligible based upon lack of income and resources. 42 U.S.C. § 1381. The goal of SSI is “to assist those who cannot work because of age, blindness, or disability.” Schweiker v. Wilson, 450 U.S. 221, 223, 101 S.Ct. 1074, 1077, 67 L.Ed.2d 186 (1981) (quoting S.Rep. No. 1230, 92d Cong., 2d Sess. 4, 12 (1972), reprinted in 1972 U.S.C.C.A.N. 4989).

When Congress created the SSI program, it made the program subject to 42 U.S.C. § 407(a). See 42 U.S.C. § 1383(d)(1). This inalienability provision states:

(a) The right of any persons to any future payment under this subehapter shall not be transferable or assignable, at law or in equity, and none of the monies paid or payable or the rights existing under this subehapter shall be subject to execution, levy, attachment, garnishment, or other legal process, or to the operation of any bankruptcy or insolvency law.

42 U.S.C. § 407(a) (emphasis added). The patent intent of this statute is to prohibit creditors from asserting claims upon SSI funds that take precedence over the SSI recipient’s rights to such funds.

To further interpret 42 U.S.C. § 407(a), it is beneficial to turn to other provisions of the same title. It is a well-settled principle of statutory construction that “[t]he court in construing any extant act may refer to prior acts or sections of the same statute relating to the same subject in ascertaining meaning of the law under consideration.” Burbank v. Sinclair Prairie Oil Co., Ky, 304 Ky. 833, 202 S.W.2d 420 (1947); see Daviess County v. Snyder, 556 S.W.2d 688 (1977) (interrelated sections of a single integrated statute must be construed in harmony with one another); Ledford v. Faulkner, Ky., 661 S.W.2d 475 (1983) (a court has a duty to harmonize apparent conflicts between statutes or sections thereof); Vogt v. City of Louisville, Ky., 258 Ky. 36, 79 S.W.2d 359 (1935) (statutes constituting part of the same subject matter should be considered together and given harmonious construction).

In 42 U.S.C. § 659, “legal process” is defined as

... any writ, order, summons, or other similar process in the nature of garnishment, which—
(1) is issued by (A) a court of competent jurisdiction within any State, territory, or possession of the United States ... and (2) is directed to, and the purpose of which is to compel, a government entity, which holds moneys which are otherwise payable to an individual, to make payment from such moneys to another party in order to satisfy a legal obligation of such individual to provide child support or make alimony payments.

42 U.S.C. § 659(e) (emphasis added). Thus, 42 U.S.C. § 659(e) supports the conclusion that the “legal process” referred to in 42 U.S.C. § 407(a) is of the nature of a garnishment order directed towards a governmental entity.

The Kentucky statute that appellee claims is in conflict with 42 U.S.C. § 407(a) lists the sources of income to be included in the child support calculation:

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Cite This Page — Counsel Stack

Bluebook (online)
984 S.W.2d 840, 1998 Ky. LEXIS 138, 1998 WL 741804, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-ex-rel-morris-v-morris-ky-1998.