Bowen v. Galbreath

Background

Mary Alice Galbreath, a financially needy SSI applicant, had her claim denied and won on appeal in district court. The Secretary paid her $7,954 in past-due SSI benefits. Her lawyer asked for 25% of those benefits ($1,988.50). The district court ordered the Secretary to withhold that amount from Galbreath’s past-due benefits under a statute used in Social Security insurance cases. The Eighth Circuit affirmed, and the case reached this Court to resolve conflicting appeals court rulings.

Reasoning

The Court examined the difference between Title II (an insurance program for insured workers) and Title XVI (a welfare program for needy individuals). When Congress created Title XVI, it copied many Title II rules but left out provisions allowing withholding of past-due benefits to pay attorneys. The legislative history shows Congress intentionally omitted administrative withholding and suggests the same for judicial withholding, given SSI recipients’ extreme financial need. A 1976 change making certain factual findings reviewable did not indicate approval of withholding. The Court rejected the idea that courts have an inherent power to order such withholding and concluded Congress, not judges, must authorize any withholding.

Real world impact

As a result, courts may not order the Secretary to withhold past-due SSI benefits to pay attorneys’ fees under current law. Needy SSI recipients keep their full past-due payments, and lawyers must pursue fees by other means unless Congress changes the law. The decision resolves a split among appeals courts and leaves any expansion of withholding authority to Congress.