In the case of James Lockhart v. United States et al., 2005, the U.S Supreme Court ruled that federal law allows for Social Security benefits to be garnished in order to repay student loans. The plaintiff, James Lockhart, had defaulted on his student loan and as a result, his Social Security disability payments were being reduced by 15% each month under the Debt Collection Improvement Act (DCIA) of 1996. He argued that this was contrary to sections of both the Social Security Act and Administrative Wage Garnishment regulations which protect such benefits from attachment or other legal process. However, the court held that amendments made by DCIA specifically permit withholding from federal payments including social security benefits for delinquent debts owed to states or agencies of the US government.

In the dissenting opinion for James Lockhart v. United States et al., Justice Breyer, joined by Justices Souter and Stevens, argued that the majority misinterpreted federal law in allowing the government to garnish social security benefits to repay student loans. The dissenters believed that Congress intended to protect these benefits from attachment or other legal process under Section 207 of Social Security Act. They pointed out that this provision was designed specifically to shield vulnerable individuals who rely on these payments as their primary means of subsistence from financial hardship. Furthermore, they contended that a later-enacted statute permitting garnishment did not explicitly repeal this protection and should not be interpreted as doing so implicitly without clear evidence of Congressional intent. Therefore, they concluded that unless Congress clearly states otherwise, courts should presume it intends its laws harmoniously rather than at odds with each other.