In Rose v. Rose, 481 U.S. 619 (1987), the court held the federal preemption doctrine did not prohibit the State of Tennessee from holding a military veteran in contempt for nonpayment of child support when the support was based on disability payments not subject to garnishment, and such payments were his only means for satisfying his support obligation. A federal statute excluded from garnishment " 'any payments by the Veterans' Administration as compensation for a service-connected disability.' " (Id. at p. 634.) The veteran argued the exclusion "embodies Congress' intent that veterans' disability benefits not be subject to any legal process aimed at diverting funds for child support, including a state-court contempt proceeding." (Id. at p. 635.) The court rejected the theory, explaining the garnishment statute did not apply to any proceeding, but rather applied to state proceedings against agencies of the United States government to attach funds held by the agencies. (Ibid.) In Rose, supra, 481 U.S. 619, 625, the United States Supreme Court explained: "We have consistently recognized that 'the whole subject of the domestic relations of husband and wife, parent and child, belongs to the laws of the States and not to the laws of the United States.' 'On the rare occasion when state family law has come into conflict with a federal statute, this Court has limited review under the Supremacy Clause to a determination whether Congress has "positively required by direct enactment" that state law be pre-empted.' Before a state law governing domestic relations will be overridden, it 'must do "major damage" to "clear and substantial" federal interests.' " The Supreme Court addressed the scope of the federal statute in considering whether a Tennessee state court had jurisdiction to hold a veteran in contempt for nonpayment of child support when the veteran's only means of satisfying the obligation was chapter 38 service-connected disability benefits. The veteran argued that various federal laws, including 38 U.S.C. 5301(a)(1), evinced a Congressional intent to preempt state statutes that give state courts jurisdiction over veterans' disability benefits. Rose, 481 U.S. at 625, 630. According to the Court, 38 U.S.C. 5301 has "two purposes: (1) to 'avoid the possibility of the Veterans' Administration . . . being placed in the position of a collection agency,'" and; (2) "to 'prevent the deprivation and depletion of the means of subsistence of veterans dependent upon these benefits as the main source of their income.'" Rose, 481 U.S. at 630, quoting S. Rep. No. 94-1243, at 147-48 (1976). The Court determined that neither of these purposes was "constrained by allowing the state court . . . to hold the veteran in contempt for failing to pay child support." Id. Specifically, the Court noted that veteran disability benefits "are intended to 'provide reasonable and adequate compensation for disabled veterans and their families.'" Id., quoting S. Rep. No. 98-604, at 24 (1984). The Court thus concluded that 38 U.S.C. 5301(a)(1) "does not extend to protect a veteran's disability benefits from seizure where the veteran invokes that provision to avoid an otherwise valid order of child support." Rose, 481 U.S. at 634. The Court also rejected the veteran's argument based on other federal laws and affirmed the contempt finding. Id. at 636. In doing so, the Court stated that, even though a veteran's disability benefits may be "exempt from garnishment or attachment while in the hands of the Administrator, we are not persuaded that once these funds are delivered to the veteran a state court cannot require that veteran to use them to satisfy an order of child support." Id. at 635.