Mackey v. Lanier Collection Agency & Service, Inc

In Mackey v. Lanier Collection Agency & Service, Inc., 486 U.S. 825, 100 L. Ed. 2d 836, 108 S. Ct. 2182 (1988), two Georgia statutes were examined by the Supreme Court. The first expressly barred garnishment of benefits of an employee benefit plan that was subject to ERISA. The second was Georgia's general garnishment statute. The Supreme Court held that the more specific statute exempting ERISA plan benefits from garnishment was preempted, even though it may have been enacted to effectuate ERISA's purposes. The Court held that the "state statute's express reference to ERISA plans suffices to bring it within the federal law's preemptive reach." But the Court held that Georgia's general garnishment statute was not preempted to the extent that it applied to welfare benefit plans as distinguished from pension benefit plans. The Supreme Court rejected the argument that because garnishment would subject plan administrators to substantial burdens and costs, the general statute "related to" ERISA benefit plans. In reaching that conclusion, the Court looked to the structure and purposes of ERISA.