WASHINGTON STATE DEPARTMENT OF SOCIAL AND HEALTH SERVICES et al. v. GUARDIAN- SHIP ESTATE OF KEFFELER et al.

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371 OCTOBER TERM, 2002
Syllabus
WASHINGTON STATE DEPARTMENT OF SOCIAL
AND HEALTH SERVICES et al. v. GUARDIAN-
SHIP ESTATE OF KEFFELER et al.
certiorari to the supreme court of washington
No. 01–1420. Argued December 3, 2002—Decided February 25, 2003
Although Old-Age, Survivors, and Disability Insurance (OASDI) bene-
fits under Title II of the Social Security Act, 42 U. S. C. § 401 et seq.,
and Supplemental Security Income (SSI) benefits under Title XVI,
§ 1381 et seq., are generally paid directly to the beneficiary, the Social
Security Administration may distribute them to another individual or
entity as the beneficiary’s “ ‘representative payee,’ ” §§ 405( j)(1)(A),
1383(a)(2)(A)(ii)(I). Regulations provide, inter alia, that social service
agencies and custodial institutions may serve as representative payees,
but follow a parent, legal guardian, or relative in the order of preference
for appointment to that position. E. g., 20 CFR §§ 404.2021(b)(7),
416.621(b)(7). Such a payee may expend funds “only for the use and
benefit of the beneficiary,” in a way the payee determines “to be in the
[beneficiary’s] best interests.” §§ 404.2035(a), 416.635(a). Payments
made for “current maintenance” are “for the use and benefit of the bene-
ficiary,” and “current maintenance” includes “cost[s] incurred in obtain-
ing food, shelter, clothing, medical care, and personal comfort items,”
§§ 404.2040(a), 416.640(a). A representative payee “may not be required
to use benefit payments to satisfy a [beneficiary’s] debt” that arose be-
fore the period the benefit payments are certified to cover, but a payee
may discharge such a debt if the beneficiary’s “current and reasonably
foreseeable needs” are met and it is in the beneficiary’s interest to do
so, §§ 404.2040(d), 416.640(d).
Washington State, through petitioner Department of Social and
Health Services, provides foster care to certain children removed from
their parents’ custody, and it also receives and manages Social Security
benefits as representative payee for many of those children. Pursuant
to its regulation requiring that public benefits for a child, including SSI
or OASDI benefits, be used on behalf of the child to help pay for the
child’s foster care costs, the department generally credits the Social Se-
curity benefits it receives to a special account for the beneficiary child,
and debits the account to pay foster care providers. Respondents, who
include such beneficiary children, filed this class action in state court,
alleging, among other things, that the department’s use of their OASDI
or SSI benefits to reimburse itself for the foster care costs violated 42

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372 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
SERVS. v. GUARDIANSHIP ESTATE OF KEFFELER
Syllabus
U. S. C. §§ 407(a) and 1383(d)(1). Section 407(a), the Act’s “antiattach-
ment” provision, protects Title II benefits from “execution, levy, attach-
ment, 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 previ-
ous 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 reim-
burse 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, garnish-
ment, 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 interpre-
tative 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 enumer-
ated by the specific words. E. g., Circuit City Stores, Inc. v. Adams,
532 U. S. 105, 114–115. Thus, “other legal process” should be under-
stood to be process much like the processes of execution, levy, attach-
ment, and garnishment, and at a minimum, would seem to require uti-
lization 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 con-
firmed by the definition of “legal process” in the Social Security Admin-
istration’s Program Operations Manual System (POMS). On this re-
strictive 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 enforce-
able obligation, the State has no enforceable claim against its foster
children. And while execution, levy, attachment, and garnishment typi-
cally involve the exercise of some sort of judicial or quasi-judicial au-
thority to gain control over another’s property, the department’s re-
imbursement 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 ac-
counting, there is no question that the funds were spent for items of

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373 Cite as: 537 U. S. 371 (2003)
Syllabus
“current maintenance” within the meaning of the regulations. That the
State is dealing with the funds consistently with the regulations is con-
firmed by the POMS. The Government has gone even further to sup-
port this as a reasonable interpretation, text aside, owing to significant
advantages of the reimbursement method in providing accurate docu-
mentation and allowing for easy monitoring of representative payees in
administering Social Security. Philpott v. Essex County Welfare Bd.,
409 U. S. 413, and Bennett v. Arkansas, 485 U. S. 395 (per curiam),
distinguished. Pp. 382–389.
(b) The Court rejects the view that this construction of § 407(a),
allowing a state agency to reimburse itself for foster care costs, is anti-
thetical to the child’s best interests. Respondents’ premise that pro-
moting those interests requires maximizing resources from left-over
benefit income ignores the settled administrative law principle that an
open-ended and potentially vague term is highly susceptible to admin-
istrative interpretation subject to judicial deference. See Chevron
U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U. S. 837,
842–843. Under her statutory authority, the Commissioner has read
the beneficiary’s “interest” in light of the Act’s basic objectives: to pro-
vide a minimum level of income to children who would not otherwise
have sufficient resources, see, e. g., Sullivan v. Zebley, 493 U. S. 521, 524,
and to provide workers and their families the income required for ordi-
nary and necessary living expenses, see, e. g., Califano v. Jobst, 434 U. S.
47, 50. The Commissioner, that is, has decided that a representative
payee serves the beneficiary’s interest by seeing that basic needs are
met, not by maximizing a trust fund attributable to fortuitously overlap-
ping state and federal grants. This judgment not only is obviously
within reasonable bounds, but is confirmed by the demonstrably anti-
thetical character of respondents’ position to the best interest of many
foster care children. If respondents prevailed, many foster children
would lose SSI benefits altogether, since eligibility for such benefits is
lost if a child’s resources creep above a certain minimal level, currently
$2,000. E. g., 20 CFR § 416.1205(c). In addition, respondents’ argu-
ment forgets that public institutions like the department are last in line
for appointment as representative payees. If respondents had their
way, public offices might well not be there to serve as payees even as the
last resort, because many States would be discouraged from accepting
appointment as representative payees by the administrative costs of
acting in that capacity. With a smaller total pool of money for their
potential use, the chances of having funds for genuine needs beyond
immediate support would obviously shrink, to the children’s loss.
Pp. 389–391.
145 Wash. 2d 1, 32 P. 3d 267, reversed and remanded.

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374 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
SERVS. v. GUARDIANSHIP ESTATE OF KEFFELER
Syllabus
Souter, J., delivered the opinion for a unanimous Court.
Christine O. Gregoire, Attorney General of Washington,
argued the cause for petitioners. With her on the briefs
were William Berggren Collins, Senior Assistant Attorney
General, Walter Dellinger, and Pamela Harris.
Patricia A. Millett argued the cause for the United States
as amicus curiae urging reversal. With her on the briefs
were Solicitor General Olson, Assistant Attorney General
McCallum, Deputy Solicitor General Kneedler, William
Kanter, and Jonathan H. Levy.
Teresa Wynn Roseborough argued the cause for respond-
ents. With her on the brief were Deborah M. Danzig, Rich-
ard B. Price, and Rodney M. Reinbold.*
*Briefs of amici curiae urging reversal were filed for the State of Flor-
ida et al. by Robert A. Butterworth, Attorney General of Florida, Thomas
E. Warner, Solicitor General, and Matthew J. Conigliaro, Deputy Solicitor
General, and by the Attorneys General for their respective jurisdictions
as follows: William H. Pryor, Jr., of Alabama, Bruce M. Botelho of Alaska,
Fiti A. Sunia of American Samoa, Janet Napolitano of Arizona, Bill
Lockyer of California, Ken Salazar of Colorado, M. Jane Brady of Dela-
ware, Thurbert E. Baker of Georgia, Earl I. Anzai of Hawaii, James E.
Ryan of Illinois, Steve Carter of Indiana, Thomas J. Miller of Iowa, Carla
J. Stovall of Kansas, Richard P. Ieyoub of Louisiana, G. Steven Rowe of
Maine, J. Joseph Curran, Jr., of Maryland, Thomas F. Reilly of Massachu-
setts, Jennifer M. Granholm of Michigan, Mike Moore of Mississippi, Jere-
miah W. (Jay) Nixon of Missouri, Don Stenberg of Nebraska, Frankie Sue
Del Papa of Nevada, Philip T. McLaughlin of New Hampshire, David
Samson of New Jersey, Eliot Spitzer of New York, Betty D. Montgomery
of Ohio, W. A. Drew Edmondson of Oklahoma, Hardy Myers of Oregon,
Anabelle Rodrı´guez of Puerto Rico, Sheldon Whitehouse of Rhode Island,
Charles M. Condon of South Carolina, Mark Barnett of South Dakota,
Paul G. Summers of Tennessee, John Cornyn of Texas, Mark L. Shurtleff
of Utah, William H. Sorrell of Vermont, Jerry W. Kilgore of Virginia,
Iver A. Stridiron of the Virgin Islands, Darrell V. McGraw, Jr., of West
Virginia, James E. Doyle of Wisconsin, and Hoke MacMillan of Wyoming;
for the Counties of the State of California et al. by Lloyd W. Pellman,
Ada Gardiner, Catherine J. Pratt, Alan K. Marks, and Julie J. Surber;

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375 Cite as: 537 U. S. 371 (2003)
Opinion of the Court
Justice Souter delivered the opinion of the Court.
At its own expense, the State of Washington provides fos-
ter care to certain children removed from their parents’ cus-
tody, and it also receives and manages Social Security bene-
fits for many of the children involved, as permitted under the
Social Security Act and regulations. The question here is
whether the State’s use of Social Security benefits to reim-
burse itself for some of its initial expenditures violates a pro-
vision of the Social Security Act protecting benefits from
“execution, levy, attachment, garnishment, or other legal
process.” 42 U. S. C. § 407(a); see § 1383(d)(1). We hold that
it does not.
I
A
The federal money in question comes under one or the
other of two titles of the Social Security Act. Title II, 49
Stat. 622, as amended, 42 U. S. C. § 401 et seq., is the Old-Age,
Survivors, and Disability Insurance (OASDI) plan of benefits
for elderly and disabled workers, and their survivors and de-
pendents. A child may get OASDI payments if, say, the
minor is unmarried and was dependent on a wage earner
entitled to OASDI benefits. § 402(d). Title XVI of the Act,
§ 1381 et seq., is the Supplemental Security Income (SSI)
scheme of benefits for aged, blind, or disabled individuals,
including children, whose income and assets fall below speci-
fied levels (the level for the latter currently being $2,000).
§§ 1381–1382; 20 CFR § 416.1205(c) (2002).
and for the Children’s Defense Fund et al. by Michael L. Martinez and
David L. Haga.
Briefs of amici curiae urging affirmance were filed for AARP by
Rochelle Bobroff and Michael Schuster; and for Omar M. Azzam et
al. by Douglas W. Grinnell, Donnie R. Cox, Dennis B. Atchley, and Paul
W. Leehey.
Marsha L. Levick filed a brief for the Juvenile Law Center et al. as
amici curiae.

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376 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
SERVS. v. GUARDIANSHIP ESTATE OF KEFFELER
Opinion of the Court
Although the Social Security Administration generally
pays OASDI and SSI benefits directly, it may distribute
them “for [a beneficiary’s] use and benefit” to another indi-
vidual or entity as the beneficiary’s “ ‘representative payee.’ ”
42 U. S. C. §§ 405( j)(1)(A), 1383(a)(2)(A)(ii)(I); see 20 CFR
§§ 404.2001, 404.2010, 416.601, 416.610. In the exercise of its
rulemaking authority, see 42 U. S. C. §§ 405(a), ( j)(2)(A)(ii),
the Administration has given priority to a child’s parent,
legal guardian, or relative when considering such an ap-
pointment. 20 CFR §§ 404.2021(b), 416.621(b). While the
Act and regulations allow social service agencies and custo-
dial institutions to serve in this capacity, such entities come
last in order of preference. §§ 404.2021(b)(7), 416.621(b)(7);
see also 42 U. S. C. §§ 405( j)(3)(F), 1383(a)(2)(D)(ii). Who-
ever the appointee may be, the Commissioner of Social
Security must be satisfied that the particular appointment
is “in the interest of ” the beneficiary. §§ 405( j)(2)(A)(ii),
1383(a)(2)(B)(i)(II).1
Detailed regulations govern a representative payee’s use
of benefits. Generally, a payee must expend funds “only for
the use and benefit of the beneficiary,” in a way the payee
determines “to be in the [beneficiary’s] best interests.”
20 CFR §§ 404.2035(a), 416.635(a). The regulations get more
1 Prior to making an appointment, the Commissioner must verify the
potential representative payee’s identity, connection to the beneficiary, and
lack of relevant criminal record or prior misuse of Social Security funds.
§§ 405( j)(2)(B), 1383(a)(2)(B)(ii); see 20 CFR §§ 404.2025, 416.625. The
Commissioner must also attempt to identify any other potential rep-
resentative payee whose appointment may be preferred. 42 U. S. C.
§§ 405( j)(2)(A)(ii), 1383(a)(2)(B)(i)(II); see 20 CFR §§ 404.2020, 416.620.
In addition, the Commissioner is required to notify the beneficiary
or the beneficiary’s legal guardian of her intention to appoint a representa-
tive payee. 42 U. S. C. §§ 405( j)(2)(E)(ii), 1383(a)(2)(B)(xii); see 20 CFR
§§ 404.2030, 416.630. “Any individual who is dissatisfied . . . with the des-
ignation of a particular person to serve as representative payee shall be
entitled to a hearing by the Commissioner,” with judicial review available
thereafter. 42 U. S. C. §§ 405( j)(2)(E)(i), 1383(a)(2)(B)(xi).

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Opinion of the Court
specific in providing that payments made for “current main-
tenance” are deemed to be “for the use and benefit of
the beneficiary,” defining “current maintenance” to in-
clude “cost[s] incurred in obtaining food, shelter, clothing,
medical care, and personal comfort items.” §§ 404.2040(a),
416.640(a). Although a representative payee “may not be
required to use benefit payments to satisfy a debt of the ben-
eficiary” that arose before the period the benefit payments
are certified to cover, a payee may discharge such a debt “if
the current and reasonably foreseeable needs of the benefi-
ciary are met” and it is in the beneficiary’s interest to do so.
§§ 404.2040(d), 416.640(d). Finally, if there are any funds left
over after a representative payee has used benefits for cur-
rent maintenance and other authorized purposes, the payee
is required to conserve or invest the funds and to hold them
in trust for the beneficiary. §§ 404.2045, 416.645.
The Act requires a representative payee to provide the
Commissioner with an accounting at least annually, 42
U. S. C. §§ 405( j)(3)(A), 1383(a)(2)(C)(i), and some institu-
tional representative payees are liable to triennial onsite
reviews by the Commissioner’s staff, see Social Security
Admin., Increased Monitoring of Fee-for-Service and Volume
Representative Payees, Policy Instruction EM–00072 (June
1, 2000). In any case, the Commissioner may order a report
any time she “has reason to believe” that a payee is misusing
a beneficiary’s funds, §§ 405( j)(3)(D), 1383(a)(2)(C)(iv), a crim-
inal offense that calls for revocation of the payee’s appoint-
ment, §§ 405( j)(1)(A), 408(a)(5), 1383(a)(2)(A)(iii), 1383a(a)(4);
see 20 CFR §§ 404.2050, 416.650.
B
The State of Washington, through petitioner Department
of Social and Health Services, makes foster care available
to abandoned, abused, neglected, or orphaned children
who have no guardians or other custodians able to care for
them adequately. See Wash. Rev. Code §§ 13.34.030(5),

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378 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
SERVS. v. GUARDIANSHIP ESTATE OF KEFFELER
Opinion of the Court
13.34.130(1)(b) (2002). Although the department provides
foster care without strings attached to any child who needs
it, the State’s policy is “to attempt to recover the costs of
foster care from the parents of [the] children,” 145 Wash. 2d
1, 6, 32 P. 3d 267, 269 (2001) (citing Wash. Rev. Code
§ 74.20A.010 (2001)), and to use “moneys and other funds” of
the foster child to offset “the amount of public assistance
otherwise payable,” § 74.13.060. The department accord-
ingly adopted a regulation providing that public benefits for
a child, including benefits under SSI or OASDI, “shall be
used on behalf of the child to help pay for the cost of the
foster care received.” Wash. Admin. Code § 388–70–069(1)
(2001), repealed by Wash. St. Reg. 01–08–047 (Mar. 30,
2001).2
When the department receives Social Security benefits as
representative payee for children in its care, it generally
credits them to a special Foster Care Trust Fund Account
kept by the state treasurer, which includes subsidiary ac-
counts for each child beneficiary. When these accounts are
debited, it is only rarely for a direct purchase by the State
of a foster child’s food, clothing, and shelter. The usual pur-
chaser is a foster care provider, who is then paid back by
the department according to a fixed compensation schedule.
Every month, the department compares its payments to the
provider of a child’s care with the child’s subsidiary account
balance, on which the department then draws to reimburse
itself. Since the State’s outlay customarily exceeds a child’s
monthly Social Security benefits, the reimbursement to the
State usually leaves the account empty until the next federal
benefit check arrives.
The department occasionally departs from this practice, in
the exercise of its discretion, to use the Social Security funds
2 In April 2001, the department repealed § 388–70–069 and replaced it
with a functionally similar provision. The new regulation provides that
the department “must use income not exempted to cover the child’s cost
of care.” Wash. Admin. Code § 388–25–0210.

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Opinion of the Court
“for extra items or special needs” ranging from orthodontics,
educational expenses, and computers, through athletic equip-
ment and holiday presents. 145 Wash. 2d, at 12, 32 P. 3d,
at 272. And there have also been exceptional instances in
which the department has forgone reimbursement for foster
care to conserve a child’s resources for expenses anticipated
on impending emancipation. See App. to Pet. for Cert.
A–57; App. 178.
C
As of September 1999, there were 10,578 foster children in
the department’s care, some 1,500 of them receiving OASDI
or SSI benefits. The Commissioner had appointed the de-
partment to serve as representative payee for almost all of
the latter children,3 who are among respondents in this ac-
tion brought on behalf of foster care children in the State
of Washington who receive or have received OASDI or SSI
benefits and for whom the department serves or has served
as representative payee. In their 1995 class action filed in
state court, they alleged, among other things, that the de-
partment’s use of their Social Security benefits to reimburse
itself for the costs of foster care violated 42 U. S. C. §§ 407(a)
and 1383(d)(1). Section 407(a), commonly called the Act’s
“antiattachment” provision, provides that
“[t]he right of any person to any future payment under
this subchapter shall not be transferable or assignable,
at law or in equity, and none of the moneys paid or pay-
able or rights existing under this subchapter shall be
subject to execution, levy, attachment, garnishment, or
other legal process, or to the operation of any bank-
ruptcy or insolvency law.”
3 Of the 1,480 children in foster care as of September 1999 who were
receiving Social Security benefits, 923 were receiving SSI benefits, 469
were receiving OASDI benefits, and 88 were receiving both, and the de-
partment acted as representative payee for 1,411.

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380 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
SERVS. v. GUARDIANSHIP ESTATE OF KEFFELER
Opinion of the Court
Section 1383(d)(1) incorporates this provision by reference
and applies it to Title XVI of the Act.
Ruling on cross-motions for summary judgment, the trial
court agreed with respondents. It enjoined the department
from continuing to charge its costs of foster care against So-
cial Security benefits, ordered restitution of previous re-
imbursement transfers, and awarded attorney’s fees to re-
spondents. The department appealed to the State Court of
Appeals, which certified the case to the Supreme Court of
Washington.
After remanding for further factfinding, the State Su-
preme Court affirmed the trial court’s holding that the de-
partment’s practices violated the antiattachment provisions.4
Relying in part on Philpott v. Essex County Welfare Bd.,
409 U. S. 413 (1973), and Bennett v. Arkansas, 485 U. S. 395
(1988) (per curiam), the state court reasoned that § 407(a)
was intended to protect Social Security benefits from the
claims of creditors, and consequently framed “the crucial
question” as “[w]hether [the department] acts as a creditor
when it reimburses itself for foster care costs out of the fos-
ter children’s [benefits].” 145 Wash. 2d, at 17, 32 P. 3d, at
275 (emphasis in original). Its answer was a slightly quali-
fied yes, that the department’s “reimbursement scheme . . .
involve[s] creditor-type acts,” performed by resort to the
“ ‘other legal process’ ” barred by § 407(a). Id., at 18, 22, 25,
32 P. 3d, at 257, 277–278.
The state court’s analysis not only gave no deference to
the Commissioner’s regulations, but omitted any mention of
4 In light of this holding, the State Supreme Court did not address re-
spondents’ other arguments, including the contention, accepted in the al-
ternative by the trial court, that the department violated procedural due
process by failing to provide notice of the “ ‘intended result’ ” of its ap-
pointment as representative payee. 145 Wash. 2d 1, 15, 32 P. 3d 267, 274
(2001) (quoting Memorandum Opinion, No. 96–2–00157–2 (Wash. Super.
Ct., Okanogan Cty., Sept. 29, 1998), p. 8, App. to Pet. for Cert. A–130).

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Opinion of the Court
the law governing rulemaking and interpretation by an ad-
ministrative agency. Nor did the state court think it sig-
nificant that it was the Commissioner of Social Security who
had appointed the department to serve as representative
payee for respondents’ Social Security benefits. See id., at
25, 32 P. 3d, at 278 (calling the department’s representative
payee status “at best immaterial to the analysis”). To the
contrary, the court ultimately reasoned that the depart-
ment’s capacity as representative payee “further undercuts
the legality of its reimbursement process” because a repre-
sentative payee is charged with acting “ ‘in the best interests
of the beneficiary.’ ” Id., at 24, 32 P. 3d, at 278 (emphasis
in original) (quoting 20 CFR § 404.2035(a)). “We seriously
doubt using [Social Security] benefits to reimburse the state
for its public assistance expenditure is in all cases, or even
some, ‘in the best interests of the beneficiary.’ ” 145 Wash.
2d, at 24, 32 P. 3d, at 278 (quoting § 404.2035(a)).5
Three justices concurred in part and dissented in part.
They agreed with the majority that the department’s use of
Social Security benefits for “past due foster care payments”
violated the antiattachment provisions of the Act. Id., at
27, 32 P. 3d, at 279 (opinion of Bridge, J.) (emphasis in origi-
nal). But they would have held that the department is enti-
tled to use benefits to pay for “current maintenance costs,
provided that any special needs of the children are satisfied
first.” Ibid. (emphasis in original).
After staying the State Supreme Court’s mandate, 535
U. S. 923 (2002), we granted certiorari, 535 U. S. 1094 (2002),
and now reverse.
5 The State Supreme Court ultimately remanded for further consider-
ation of the scope and basis for awarding attorney’s fees. Our jurisdic-
tion, which is premised on a “[f]inal judgmen[t] or decre[e]” within the
meaning of 28 U. S. C. § 1257(a), is unaffected by this disposition. See
Pierce County v. Guillen, ante, at 142–143.

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382 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
SERVS. v. GUARDIANSHIP ESTATE OF KEFFELER
Opinion of the Court
II
A
Section 407(a) protects SSI and OASDI benefits from
“execution, levy, attachment, garnishment, or other legal
process.” The Supreme Court of Washington approached
respondents’ claim by generalizing from this text and
concluding that § 407(a) prohibits “creditor-type acts,” on
which reading it held that the department’s reimbursement
scheme was prohibited. The analysis was flawed.
First, neither § 407(a) nor the Commissioner’s regulations
interpreting that provision say anything about “creditors.”
Cf. Philpott, supra, at 417 (“[Section] 407 does not refer to
any ‘claim of creditors’; it imposes a broad bar against the
use of any legal process to reach all social security benefits”).
In fact, the Act and regulations to which we owe deference,
see Chevron U. S. A. Inc. v. Natural Resources Defense
Council, Inc., 467 U. S. 837, 842–843 (1984), not only permit
certain creditors to serve as representative payees, 42
U. S. C. §§ 405( j)(2)(C)(iii), 1383(a)(2)(B)(v), but allow a repre-
sentative payee to satisfy even old debts of a beneficiary so
long as current and reasonably foreseeable needs will be met
and reimbursement is in the beneficiary’s interest, 20 CFR
§§ 404.2040(d), 416.640(d). Finally, as the Supreme Court of
Washington apparently recognized (in qualifying its charac-
terization of “creditor relationship” by referring to the de-
partment’s acts as merely “creditor-type”), the department
is simply not a creditor of the foster care children for whom
it serves as representative payee. No law provides that
they are liable to repay the department for the costs of their
care, and the State of Washington makes no such claim.
The questions to be answered in resolving this case, then,
do not go to the State’s character as a creditor. The ques-
tions, instead, are whether the department’s effort to become
a representative payee, or its use of respondents’ Social Se-
curity benefits when it acts in that capacity, amounts to em-

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ploying an “execution, levy, attachment, garnishment, or
other legal process” within the meaning of § 407(a).6 For ob-
vious reasons, respondents do not contend that the depart-
ment’s activities involve any execution, levy, attachment, or
garnishment. These legal terms of art refer to formal pro-
cedures by which one person gains a degree of control over
property otherwise subject to the control of another, and
generally involve some form of judicial authorization. See,
e. g., Black’s Law Dictionary 123 (7th ed. 1999) (defining “pro-
visional attachment” as a “prejudgment attachment in which
the debtor’s property is seized so that if the creditor ulti-
mately prevails, the creditor will be assured of recovering on
the judgment . . . . Ordinarily, a hearing must be held be-
fore the attachment takes place”); id., at 689 (defining “gar-
nishment” as “[a] judicial proceeding in which a creditor (or
potential creditor) asks the court to order a third party who
is indebted to or is bailee for the debtor to turn over to the
creditor any of the debtor’s property”). The department’s
efforts to become a representative payee and to use respond-
ents’ benefits do not even arguably employ any of these tra-
ditional procedures.
Thus, the case boils down to whether the department’s
manner of gaining control of the federal funds involves
“other legal process,” as the statute uses that term. That
restriction to the statutory usage of “other legal process” is
6 Respondents have apparently never argued that the reimbursement
violates the § 407(a) bar to “transfe[r]” of benefits; nor would such a claim
seem to hold any promise on the facts here. Respondents do, however,
contend that the department’s budgeting in anticipation of receiving Social
Security benefits constitutes an “assign[ment]” prohibited by § 407(a).
Congress could hardly have intended for this sort of budgeting, done by
private and public representative payees alike, to run afoul of the antiat-
tachment provisions of the Act, particularly since the Administration
makes OASDI payments with a 1-month lag. See infra, at 387. To the
extent that the text of § 407(a) is ambiguous on this score, the Commission-
er’s interpretation of the provision to permit such budgeting requires def-
erence. See Skidmore v. Swift & Co., 323 U. S. 134, 139–140 (1944).

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384 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
SERVS. v. GUARDIANSHIP ESTATE OF KEFFELER
Opinion of the Court
important here, for in the abstract the department does use
legal process as the avenue to reimbursement: by a federal
legal process the Commissioner appoints the department a
representative payee,7 and by a state legal process the de-
partment makes claims against the accounts kept by the
state treasurer. The statute, however, uses the term “other
legal process” far more restrictively, for under the estab-
lished interpretative canons of noscitur a sociis and ejusdem
generis, “ ‘[w]here general words follow specific words in a
statutory enumeration, the general words are construed to
embrace only objects similar in nature to those objects enu-
merated by the preceding specific words.’ ” Circuit City
Stores, Inc. v. Adams, 532 U. S. 105, 114–115 (2001); see Gu-
tierrez v. Ada, 528 U. S. 250, 255 (2000) (“[W]ords . . . are
known by their companions”); Jarecki v. G. D. Searle & Co.,
367 U. S. 303, 307 (1961) (“The maxim noscitur a sociis . . .
is often wisely applied where a word is capable of many
7 Quite apart from any consequence of the interpretive canons discussed
in the succeeding text, the mere fact of the department’s appointment
as representative payee could not reasonably be taken to contravene the
antiattachment provision, contrary to respondents’ suggestion. As al-
ready noted, the department’s appointment is consistent with the sections
of the Act governing appointment of representative payees, see 42 U. S. C.
§§ 405( j)(2)(C), (3)(B) and (F), (4)(B), 1383(a)(2)(B)(v), (vii)(II), (C)(ii),
(D)(ii), and with the Commissioner’s regulations interpreting that section
to authorize appointment of custodial institutions as a last resort, see 20
CFR §§ 404.2021(b)(7), 416.621(b)(7). To suggest that the department’s
appointment as representative payee, under the same statutory scheme
that forbids the use of “other legal process,” is itself forbidden legal proc-
ess disregards the “cardinal rule that a statute is to be read as a whole,”
King v. St. Vincent’s Hospital, 502 U. S. 215, 221 (1991), and ignores the
Commissioner’s reasonable regulations implementing the Act. See King
v. Schafer, 940 F. 2d 1182, 1185 (CA8 1991) (“We cannot believe Congress
contemplated this result in enacting § 407(a), particularly when this result
would be contrary to another provision of the Social Security Act: § 405( j),
providing for the appointment of representative payees”), cert. denied
sub nom. Crytes v. Schafer, 502 U. S. 1095 (1992); 940 F. 2d, at 1185 (“Sec-
tion 407(a) was not intended to outlaw a procedure expressly authorized
by the Social Security Administration’s own regulations”).

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meanings in order to avoid the giving of unintended breadth
to the Acts of Congress”). 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 elabo-
rate 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.
In this case, the product of these canons of construction
is confirmed by legal guidance in the Commissioner’s own
interpretation of “legal process.” The Social Security Ad-
ministration’s Program Operations Manual System (POMS),
the publicly available operating instructions for processing
Social Security claims, defines “legal process” as used in
§ 407(a) as “the means by which a court (or agency or official
authorized by law) compels compliance with its demand;
generally, it is a court order.” POMS GN 02410.001 (2002),
available at http://policy.ssa.gov/poms.nsf/aboutpoms (as vis-
ited Jan. 23, 2003) (available in Clerk of Court’s case file).
Elsewhere in the POMS, the Commissioner defines “legal
process” similarly as “any writ, order, summons or other sim-
ilar process in the nature of garnishment. It may include,
but is not limited to, an attachment, writ of execution, in-
come execution order or wage assignment that is issued by
. . . [a] court of competent jurisdiction . . . [or a]n authorized
official pursuant to an order of a court of competent jurisdic-
tion or pursuant to State or local law . . . [a]nd is directed
to a governmental entity.” POMS GN 02410.200 (emphasis
added). While these administrative interpretations are not
products of formal rulemaking, they nevertheless warrant
respect in closing the door on any suggestion that the usual
rules of statutory construction should get short shrift for the
sake of reading “other legal process” in abstract breadth.
See Skidmore v. Swift & Co., 323 U. S. 134, 139–140 (1944);

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386 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
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Opinion of the Court
see also United States v. Mead Corp., 533 U. S. 218, 228, 234–
235 (2001).
On this restrictive understanding of “other legal process,”
it is apparent that the department’s efforts to become re-
spondents’ representative payee and its use of respondents’
benefits in that capacity involve nothing of the sort.8
Whereas the object of the processes specifically named is to
discharge, or secure discharge of, some enforceable obliga-
tion, the State has no enforceable claim against its foster
children. And although execution, levy, attachment, and
garnishment typically involve the exercise of some sort of
judicial or quasi-judicial authority to gain control over anoth-
er’s property, the department’s reimbursement scheme oper-
ates on funds already in the department’s possession and
control, held on terms that allow the reimbursement.
The regulations previously quoted specify that payments
made for a beneficiary’s “current maintenance” are deemed
to be “for the use and benefit of the beneficiary,” and define
“current maintenance” to include “cost[s] incurred in obtain-
ing food, shelter, clothing, medical care, and personal comfort
items.” 20 CFR §§ 404.2040(a), 416.640(a). There is no
question that the state funds to be reimbursed were spent
for items of “current maintenance,” and although the State
typically makes the accounting reimbursement two months
after spending its own funds, this practice is consistent with
the regulation’s definition of “current maintenance” as “costs
incurred” for food and the like. That the State is dealing
with the funds consistently with Social Security regulations
is confirmed by the Commissioner’s own interpretation of
8 In arguing that § 407(a) applies here, respondents rely in part on
§ 407(b), which provides that “[n]o other provision of law . . . may be con-
strued to limit, supersede, or otherwise modify the provisions of this sec-
tion except to the extent that it does so by express reference to this sec-
tion.” Given our conclusion that § 407(a), by its terms, does not apply,
however, respondents’ reliance is misplaced.

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those regulations as allowing reimbursement by a repre-
sentative payee for maintenance costs, at least for costs in-
curred after the first benefit payment is made to the payee.
Cf. POMS GN 00602.030 (defining a “past debt,” which may
be satisfied only if a beneficiary’s current and reasonably
foreseeable needs are met, as “a debt the beneficiary in-
curred before the date of the first benefit payment is made
to the current payee”).9
The Government has gone even further to support this as
a reasonable interpretation, text aside, owing to significant
advantages of the reimbursement method in providing accu-
rate documentation and allowing for easy monitoring of rep-
resentative payees in administering Social Security. See
Brief for United States as Amicus Curiae 28–29.10 In fact,
it would be hard not to see this type of slightly delayed reim-
bursement as the only way OASDI funds could be spent on a
foster child’s current maintenance, since the Administration
disburses those Social Security benefits with a time lag.
See POMS GN 02401.001 (noting that OASDI benefits are
dispensed within the month after they are due). In short,
the Commissioner’s interpretation of her own regulations is
9 There is one exception to this rule, although it is not relevant for
our present purposes. In October 1996, Congress amended 42 U. S. C.
§ 1383 to specify that when the Administration issues a retroactive lump
sum payment of SSI benefits that exceeds six times the monthly
benefit amount, that amount is to be deposited directly into a dedicated
interest-bearing bank account to be used only for certain special needs.
§ 1383(a)(2)(F).
10 Moreover, as the Government notes, the position of the Supreme
Court of Washington and respondents is ultimately “one of empty formal-
ism” because a State could, indisputably, use a foster child’s Social Security
benefits directly for the costs of care and then reduce the State’s own
funding by the same amount. Brief for United States as Amicus Curiae
28. The financial result would be the same as in the system currently
used by the department, yet the practical advantages of the reimburse-
ment method of accounting would be lost.

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388 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
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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 con-
clusion, 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 reimburse-
ment 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 sepa-
rate 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 mainte-
nance 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 pro-
hibited 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 reason-
ing 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 obliga-
tion 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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bursement for the costs incurred in providing for the benefi-
ciary’s care and maintenance.
B
The poor fit between § 407(a) and respondents’ argument
points to the real basis of their objections to the reimburse-
ment practice. At bottom, respondents’ position and the
State Supreme Court’s holding reflect a view that allowing
a state agency to reimburse itself for the costs of foster care
is antithetical to the best interest of the beneficiary foster
child. See 145 Wash. 2d, at 17, 32 P. 3d, at 275 (contending
that a foster child “is better off with any payee other than
the [department] because [the department] must provide fos-
ter care under state law regardless of whether it receives a
reimbursement” (emphasis in original)); id., at 24, 32 P. 3d,
at 278 (“We seriously doubt using [Social Security] benefits
to reimburse the state for its public assistance expenditure
is in all cases, or even some, ‘in the best interests of the
beneficiary’ ” (quoting 20 CFR § 404.2035(a))).
Although it is true that the State could not directly compel
the beneficiary or any other representative payee to pay So-
cial Security benefits over to the State, that fact does not
render the appointment of a self-reimbursing representative
payee at odds with the Commissioner’s mandate to find that
a beneficiary’s “interest . . . would be served” by the appoint-
ment. 42 U. S. C. §§ 405( j)(1)(A), 1383(a)(2)(A)(ii)(I).12 Re-
12 Respondents also go beyond the § 407(a) issue to argue that the de-
partment violates § 405( j) itself, by, for example, failing to exercise discre-
tion in how it uses benefits, periodically “sweeping” beneficiaries’ accounts
to pay for past care, and “double dipping” by using benefits to reimburse
the State for costs previously recouped from other sources. These allega-
tions, and respondents’ § 405( j) stand-alone arguments more generally, are
far afield of the question on which we granted certiorari. Moreover, con-
stitutional claims aside, respondents’ complaint and the class-action certi-
fication related only to § 407(a). Accordingly, we decline to reach respond-
ents’ § 405( j) arguments here, except insofar as they relate to the proper
interpretation of § 407(a). Respondents are free to press their stand-

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390 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
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Opinion of the Court
spondents’ premise that promoting the “best interests” of
a beneficiary requires maximizing resources from left-over
benefit income ignores the settled principle of administrative
law that an open-ended and potentially vague term is highly
susceptible to administrative interpretation subject to judi-
cial deference. See Chevron, 467 U. S., at 842–843. Under
her statutory authority, the Commissioner has read the “in-
terest” of the beneficiary in light of the basic objectives of
the Act: to provide a “minimum level of income” to children
who would not “have sufficient income and resources to
maintain a standard of living at the established Federal mini-
mum income level,” 20 CFR § 416.110 (SSI); see also Sulli-
van v. Zebley, 493 U. S. 521, 524 (1990), and to provide work-
ers and their families the “income required for ordinary and
necessary living expenses,” § 404.508(a) (OASDI); see also
Califano v. Jobst, 434 U. S. 47, 50 (1977). The Commis-
sioner, that is, has decided that a representative payee
serves the beneficiary’s interest by seeing that basic needs
are met, not by maximizing a trust fund attributable to for-
tuitously overlapping state and federal grants.
This judgment is not only obviously within the bounds of
the reasonable, but one confirmed by the demonstrably anti-
thetical character of respondents’ position to the best inter-
est of many foster care children. SSI beneficiaries would be
most obviously subject to threat, since eligibility for benefits
of these child recipients is lost if their assets creep above
a certain minimal level, currently $2,000. See 42 U. S. C.
§§ 1382(a)(1)(B), (3)(B); 20 CFR § 416.1205(c). Many foster
children would lose SSI benefits altogether if respondents
prevailed. See Brief for Children’s Defense Fund et al. as
Amici Curiae 20; Brief for Counties of the State of Califor-
nia et al. as Amici Curiae 16–18. But foster children bene-
ficiaries under both SSI and OASDI would suffer from a
broader disadvantage. Respondents’ argument forgets the
alone § 405( j) arguments before the Commissioner, who bears responsibil-
ity for overseeing representative payees, or elsewhere as appropriate.

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fact that public institutions like the department are last in
the line of eligibility for appointment as representative pay-
ees; the Commissioner appoints them only when no one else
will do. See 20 CFR §§ 404.2021(b), 416.621(b). If respond-
ents had their way, however, public offices like the depart-
ment might well not be there to serve as payees even as the
last resort, for there is reason to believe that if state agencies
could not use Social Security benefits to reimburse the State
in funding current costs of foster care, many States would be
discouraged from accepting appointment as representative
payees by the administrative costs of acting in that capacity.
See Brief for Children’s Defense Fund, supra, at 21; Brief
for State of Florida et al. as Amici Curiae 7. 13 And without
such agencies to identify children eligible for federal benefits
and to help them qualify, see Brief for Children’s Defense
Fund, supra, at 20–24; Brief for State of Florida, supra, at
3–5; Brief for United States as Amicus Curiae 17, many eli-
gible children would either obtain no Social Security benefits
or need some very good luck to get them. With a smaller
total pool of money for their potential use, the chances of
having funds for genuine needs beyond immediate support
would obviously shrink, to the children’s loss. Respondents’
position, in sum, would tend to produce worse representative
payees in these cases, with less money to spend.
13 The Act does allow a state representative payee to use the lesser of
10 percent of monthly benefits or $25 per month to offset administrative
expenses. See 42 U. S. C. §§ 405( j)(4)(A)(i), 1383(a)(2)(D)(i). Neverthe-
less, at least with respect to SSI, many States spend considerably more
to identify eligible foster children and assist them in obtaining benefits.
According to the department, for example, the process of screening poten-
tial SSI applicants among foster children and applying for benefits on their
behalf involves 27 staff members and costs $1.9 million annually. See Ap-
plication to Recall and Stay the Mandate of the Supreme Court of Wash-
ington Pending Certiorari, No. 01A557, pp. 18–19. For this reason, the
department has said that it would not seek to become the representative
payee for SSI beneficiaries absent an ability to use benefits to recoup some
costs. See ibid.

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392 WASHINGTON STATE DEPT. OF SOCIAL AND HEALTH
SERVS. v. GUARDIANSHIP ESTATE OF KEFFELER
Opinion of the Court
III
The department’s reimbursement from respondents’ Social
Security benefits does not violate § 407(a). The judgment of
the Supreme Court of Washington is reversed, and the case
is remanded for further proceedings not inconsistent with
this opinion.
It is so ordered.