In State Treasurer v. Abbott, 468 Mich. 143, 660 N.W.2d 714, 723 (Mich. 2003), the Court held ERISA does not protect pension funds once the funds are deposited in an inmate's prison account. The Michigan court stated: "We also prefer the approach adopted by the overwhelming majority of federal courts. Once pension funds are deposited in an inmate's account, ERISA does not protect them. We agree with the Guidry II court that the text of subsection 206(d)(1) does not address whether benefits that the pensioner has already received are protected. The statute's silence on this issue requires deference to the reasonable interpretation set forth in the Treasury Department regulation. That regulation clarifies that the statute protects against the alienation or assignment of rights against the plan itself. Other statutory schemes, including the Social Security Act, clearly protect benefits after their receipt. Congress did not include such expansive language in ERISA." Id. at 723.