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Albert Whitney Coburn v. Lara Brooke Seefeldt

IFP petition · Court of Appeals of Washington, Division 1, No. 86502-1-I · judgment March 10, 2025


Certiorari denied · May 4, 2026

Questions presented

  1. Whether the Fourteenth Amendment permits a state court to impose civil contempt for nonpayment without making the ability-to-pay findings required by Turner v. Rogers and Bearden v. Georgia, even when the court openly admits it lacks the financial information necessary to determine ability to comply.

  2. Whether the Consumer Credit Protection Act (CCPA), 15 U.S.C. § 1673, preempts a state court contempt order enforcing an obligation that requires withholding far in excess of federal garnishment limits, despite Congress’s express prohibition on any court making or enforcing an order that violates those limits.

  3. Whether a state court may impose contempt sanctions for nonpayment of private school tuition after the State’s Title IV-D agency has refused to enforce that obligation as child support under federal law, and where the state court simultaneously classified the same obligation as both “not child support” (to avoid federal protections) and “child support” (to impose contempt).

  4. Whether a state court may compel a parent to fund private school tuition for a disabled child—at a school not bound by IDEA—without evaluating educational necessity, appropriateness, efficacy, or the child’s right to a Free Appropriate Public Education under federal law. PARTIES TO THE PROCEEDING Petitioner is Albert Whitney Cobum, appellant in the Washington Court of Appeals and petitioner in the Washington Supreme Court. Respondent is Lara Brooke Seefeldt, respondent in the Washington Court of Appeals and respondent in the Washington Supreme Court.

Counsel of record

For petitioner
Albert Coburn

For respondent

Case

Conference history
Distributed for 1 conference

Linked docket
25A646

Proceedings

  1. May 04 2026
    Petition DENIED.
  2. Apr 16 2026
    DISTRIBUTED for Conference of 5/1/2026.
  3. Jan 31 2026
    Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due April 2, 2026)
  4. Dec 03 2025
    Application (25A646) granted by Justice Kagan extending the time to file until January 31, 2026.
  5. Nov 20 2025
    Application (25A646) to extend the time to file a petition for a writ of certiorari from December 2, 2025 to January 31, 2026, submitted to Justice Kagan.