## Facts

- Members of a pension plan committee administered an ERISA-regulated pension plan for a retired employee, George Allen Cozart.
- A New York Family Court had previously ordered Cozart to pay spousal and child support; he accumulated substantial arrears over many years.
- Rockland County provided public assistance and became assignee of the family’s support rights.
- After Cozart retired and began receiving pension payments, the Family Court issued a corrected payroll deduction order directing the pension committee to withhold $35 per week from his pension to satisfy support arrears.
- The pension committee filed a federal action against the Family Court judge, the county support collection unit, and the former spouse, seeking to enjoin enforcement of the deduction order as barred by ERISA’s anti-assignment/anti-alienation provisions.

## Issues

1. Whether ERISA’s anti-assignment and anti-alienation provisions preclude enforcement of a state court payroll deduction order garnishing pension benefits to satisfy spousal and child support arrears, including arrears assigned to a county welfare agency.

## Decision

- The court denied the pension committee’s request for injunctive relief.
- The court dismissed the action on the merits.
- The court held that ERISA’s anti-alienation protections do not bar enforcement of valid state court orders for family support obligations.

## Legal Principles

- ERISA’s anti-assignment/anti-alienation provisions are construed to allow an implied exception for court-ordered enforcement of spousal and child support obligations.
- Federal statutes are generally not read to displace state domestic-relations authority absent clear congressional intent, particularly regarding support enforcement.
- Statutory exemptions from creditors’ claims are commonly interpreted to permit satisfaction of family support duties, and ERISA is interpreted consistently with that approach.
- ERISA’s protective purposes include safeguarding employees’ families; interpreting the statute to shield a delinquent obligor from support enforcement would conflict with that purpose.
- Enforcement may extend to support rights assigned to a government agency seeking reimbursement of public assistance paid for dependents.

## Conclusion

The court permitted state enforcement of a payroll deduction order against ERISA pension payments for long-standing support arrears, concluding ERISA’s anti-alienation rule does not prevent garnishment to satisfy spousal and child support obligations, including claims assigned to a county welfare agency.


Cartledge v. Miller, 457 F. Supp. 1146 (S.D.N.Y. 1978)