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Syllabus
U. S. C. §§ 407(a) and 1383(d)(1). Section 407(a), the Act's "antiattachment" provision, protects Title II benefits from "execution, levy, attachment, garnishment, or other legal process." Section 1383(d)(1) applies § 407(a) to Title XVI. In granting respondents summary judgment, the trial court enjoined the department from continuing to charge its foster care costs against Social Security benefits, ordered restitution of previous reimbursement transfers, and awarded attorney's fees. The State Court of Appeals certified the case to the Washington Supreme Court, which ultimately affirmed the trial court's holding that the department's practices violated the antiattachment provisions.
Held: The State's use of respondents' Social Security benefits to reimburse itself does not violate 42 U. S. C. § 407(a). Pp. 382-392.
(a) Neither the department's effort to become a representative payee, nor its use of respondents' Social Security benefits when it acts in that capacity, amounts to employing an "execution, levy, attachment, garnishment, or other legal process" under § 407(a). Because the department's activities do not involve any of the specified formal procedures, the case boils down to whether those activities are "other legal process." The statute uses that term restrictively, for under the established interpretative canons of noscitur a sociis and ejusdem generis, where general words follow specific words in a statutory enumeration, the general words are construed to embrace only objects similar to those enumerated by the specific words. E. g., Circuit City Stores, Inc. v. Adams, 532 U. S. 105, 114-115. Thus, "other legal process" should be understood to be process much like the processes of execution, levy, attachment, and garnishment, and at a minimum, would seem to require utilization of some judicial or quasi-judicial mechanism, though not necessarily an elaborate one, by which control over property passes from one person to another in order to discharge or secure discharge of an allegedly existing or anticipated liability. This conclusion is confirmed by the definition of "legal process" in the Social Security Administration's Program Operations Manual System (POMS). On this restrictive understanding, it is apparent that the department's activities do not involve "legal process." Whereas the object of the specifically named processes is to discharge, or secure discharge of, some enforceable obligation, the State has no enforceable claim against its foster children. And while execution, levy, attachment, and garnishment typically involve the exercise of some sort of judicial or quasi-judicial authority to gain control over another's property, the department's reimbursement scheme operates on funds already in the department's possession and control, held on terms that allow the reimbursement. Additionally, although the State uses a reimbursement method of accounting, there is no question that the funds were spent for items of
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