388
Opinion of the Court
eminently sensible and should have been given deference under Auer v. Robbins, 519 U. S. 452, 461 (1997).11
The Supreme Court of Washington rested its contrary conclusion, in part, on our decisions in Philpott v. Essex County Welfare Bd., 409 U. S. 413 (1973), and Bennett v. Arkansas, 485 U. S. 395 (1988) (per curiam). But both Philpott and Bennett involved judicial actions in which a State sought to attach a beneficiary's Social Security benefits as reimbursement for the costs of the beneficiary's care and maintenance. See Philpott, supra, at 415 ("Respondent sued to reach the bank account"); Bennett, supra, at 396 ("The State filed separate actions in state court seeking to attach Social Security benefits"). In each case, we held that the plain language of § 407(a) barred the State's legal action, and refused to find an implied exception to the antiattachment provision for a State simply because it provides for the care and maintenance of a beneficiary. See Philpott, supra, at 416; Bennett, supra, at 397. Unlike the present case, then, both Philpott and Bennett involved forms of legal process expressly prohibited by § 407(a). In neither case was the State acting as a representative payee in seeking to use the funds as reim-11 It bears mentioning that nothing in the State Supreme Court's reasoning limits its holding to state agencies. The state court's logic would apply equally to parents serving as representative payees, since they, like the department, are under a legal obligation to support their children's basic needs irrespective of Social Security benefits. See, e. g., Wash. Rev. Code § 74.20A.010 (2002). We find it hard to believe that Congress would have intended this result, which would likely impose onerous and absurd accounting requirements on parents. See, e. g., Mellies v. Mellies, 249 Kan. 28, 33, 815 P. 2d 114, 117 (1991) (holding that a parent "had no obligation to exhaust his personal finances in providing for [his child's] support before spending any of [the child's] social security benefits on the child's maintenance"); In re Guardianship of Nelson, 547 N. W. 2d 105, 108, 109 (Minn. Ct. App. 1996) (stating that because Social Security benefits are "not a windfall" for the beneficiary, "a representative payee parent can use his or her child's social security survivor benefits for the child's current maintenance regardless of the parent's financial ability to meet those needs").
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