Dias v. Sacramento County Welfare Department (In re Dias)

70 B.R. 424, 1987 Bankr. LEXIS 255
CourtUnited States Bankruptcy Court, E.D. California
DecidedFebruary 20, 1987
DocketBankruptcy Nos. 285-01936-B-7, 285-01937-B-7; Adv. Nos. 286-0311, 286-0261
StatusPublished

This text of 70 B.R. 424 (Dias v. Sacramento County Welfare Department (In re Dias)) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dias v. Sacramento County Welfare Department (In re Dias), 70 B.R. 424, 1987 Bankr. LEXIS 255 (Cal. 1987).

Opinion

MEMORANDUM OPINION AND DECISION

DAVID E. RUSSELL, Bankruptcy Judge.

Introduction

These two cases represent yet another skirmish in the continuing battle between Social Security beneficiaries and state welfare agencies over the rights to payments from the Social Security Administration (SSA). The fact pattern and issues before the Court are the same as those in Vazquez, Guerrero and Compton, 42 B.R. 609 (Bankr.E.D.Pa.1984) (Vazquez I) which was reversed by the District Court, with the reversal being affirmed upon further appeal in Vazquez, Guerrero and Compton, 788 F.2d 130 (3rd Cir.1986) (Vazquez III).

Statement of Facts

Both petitions in bankruptcy were filed on May 21, 1985. Prior thereto the debtors had applied for Supplementary Security Income (SSI) under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381, et seq. While waiting for their applications to be processed, the debtors applied for the more immediately available General Assistance benefits (GA) from the Sacramento County Welfare Department (SCWD). At SCWD’s request, the debtors executed form SSP 14, the last one being executed by debtor Dias on October 17, 1984. The original of each executed form was sent to the SSA.

After the petitions were filed, the Appeals Council of the SSA approved the debtors’ eligibility for SSI following remand by the United States District Court for the Eastern District of California. Thereafter, and in the following sequential order, SCWD received the debtors’ first SSI checks directly from the SSA, deducted the claimed amounts of GA benefits previously paid to the debtors ($5,674.50 in the [426]*426case of Dias and $5,964.00 in the case of Williams), remitted the differences to the debtors ($4,297.33 and $3,996.30, respectively), the debtors were granted their discharges, the cases were closed and then reopened upon the debtors’ applications to file complaints to determine the discharge-ability of the SCWD debts, the debtors filed their complaints, and SCWD filed its answers.

SCWD was the only creditor listed on both of the debtors’ schedules; on A-3 as unsecured. SCWD did not file a claim nor otherwise participate in either of the bankruptcy cases until it was served with the debtors’ complaints. The SSI benefits were claimed as exempt by both debtors.

The debtors have now filed motions for summary judgment, requesting a determination that their debts to SCWD are discharged and requesting orders requiring SCWD to pay over the withheld SSI benefits to them, as was done in Vazquez I. Because the issues and the essential facts are the same, the motions were consolidated for hearing and decision.

Discussion

The key problem in these SSI cases is the proper characterization of the transaction that occurred when the debtors executed form SSP 14 and the executed original was mailed by SCWD to the SSA. Once the nature of that transaction is correctly understood, the proper decision is easily reached by the application of general bankruptcy law. The two essential elements of the transaction are the subject matter and the intention of the parties. The SSI benefits are the subject matter of the transaction. Like all Social Security benefits, they are federal funds created by Congress for the benefit of a limited class of natural persons, the distribution of' which is strictly limited to the intended beneficiaries.1 The SSA administers the Social Security program and distributes the SSI benefits under the aegis of the Secretary of Health, Education and Welfare.

The written agreement as set forth' in form SSP 14 2 is the best evidence as to the intent of the parties. That form, and form PA 176-S discussed in the Vazquez cases, are essentially the same, and both were obviously drafted to comply with the regulations set forth at 20 C.F.R. § 416.1910.3 That section of the Federal Regulations was promulgated by the Secretary of Health, Education and Welfare under the [427]*427authority of 42 U.S.C. § 1383(g)(4), which specifies the agreement that a state must have with the SSA in order to receive the SSI benefits directly from the SSA. Thus, form SSP 14 is really an agreement between three parties, the debtor-SSI beneficiary, SCWD and SSA.

Since the subject matter of the subject transaction is a federally created fund and the intent of the three parties to the transaction is evidenced by a federally mandated form, the transaction cannot be analyzed without considering the federal policy and Congressional intent underlying that fund and that form. An excellent analysis of Congressional intent and federal policy for the purpose of our analysis is set forth in the case of Moore v. Colautti, 483 F.Supp. 357 (E.D.Pa.1979).

One of the major problems of the SSI program was the deleterious effect on the impecunious beneficiaries of the time lag between the application for benefits and the first benefit check. Although the general proscription against the assignment of Social Security benefits contained in 42 U.S.C. § 407 was specifically incorporated in the SSI program by 42 U.S.C. § 1383(d)(1), the SSA and state welfare agencies cooperated to help solve the time gap problem by permitting the states to collect SSI benefits directly from the SSI beneficiaries. Under this cooperative plan, the states would provide its locally derived funds to SSI applicants until they received their first SSI benefit check. Since the initial check included retroactive benefits, the states could usually recoup their limited welfare funds paid to the SSI beneficiaries during the gap period directly from those beneficiaries. However, the case of Philpott v. Essex County Welfare Board, 409 U.S. 413, 93 S.Ct. 590, 34 L.Ed.2d 608 (1973) directly held that the states were barred, like all others, by the anti-assignment provisions of 42 U.S.C. § 407. Congress responded in 1974 by enacting the Interim Assistance Reimbursement Program (IAR) 42 U.S.C. § 1383(g). Subpara-graph (1) of that section specifically excepts the IAR program from the anti-assignment prohibition. See Moore v. Colautti, supra, pp. 362-64.

The primary reason for the IAR program was to encourage the states to provide interim assistance to SSI applicants during the gap period. It also promoted the efficient use of the limited federal and state funds for the relief of one of the most needy group of citizens while preventing that group from “double-dipping” into both funds.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
70 B.R. 424, 1987 Bankr. LEXIS 255, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dias-v-sacramento-county-welfare-department-in-re-dias-caeb-1987.