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Jon Lawrence Frank v. United States

Paid petition · United States Court of Appeals for the Fourth Circuit, No. 22-6806 · judgment February 7, 2023


Certiorari denied · October 2, 2023
Pre-decision estimate: 4% cert probability

Before the decision, roughly the 4.1% base rate. The model weighted this up for a circuit split argued in the petition, a dissent in the court below (flagged in the petition), and a Fourth Circuit decision below.

Questions presented

  1. Whether the Employee Retirement Income Security Act, pursuant to which retirement plan benefits “may not be assigned or alienated,” 29 U.S.C. § 1056(d)(1), precludes the government from garnishing an individual’s 401(k) plan account to satisfy a restitution order under the Mandatory Victims Restitution Act.

  2. Whether a lump-sum distribution from a 401(k) plan account constitutes “earnings” subject to the 25 percent cap on garnishment under the Consumer Credit Protection Act, 15 U.S.C. §§ 1672(a), 1673(a).

Counsel of record

For petitioner
Patrick L. Bryant
Office of the Federal Public Defender

For respondent
Elizabeth B. Prelogar
Solicitor General

Case

Conference history
Distributed for 1 conference

Linked docket
22A876

Proceedings

  1. Oct 02 2023
    Petition DENIED.
  2. Jun 21 2023
    DISTRIBUTED for Conference of 9/26/2023.
  3. Jun 15 2023
    Waiver of right of respondent United States of America to respond filed.
  4. Jun 07 2023
    Petition for a writ of certiorari filed. (Response due July 10, 2023)
  5. Apr 06 2023
    Application (22A876) granted by The Chief Justice extending the time to file until June 7, 2023.
  6. Apr 04 2023
    Application (22A876) to extend the time to file a petition for a writ of certiorari from May 8, 2023 to June 7, 2023, submitted to The Chief Justice.