City of Richland v. Wakefield
186 Wash. 2d 596
| Wash. | 2016Background
- Briana Wakefield, a 27-year-old homeless, disabled SSI recipient ($710/month) with additional food assistance, had three misdemeanor convictions and discretionary legal financial obligations (LFOs) for two of them.
- She moved under RCW 10.01.160(4) to remit costs, arguing she lacked present and future ability to pay and that payment would cause manifest hardship.
- At a fine-review hearing the cities did not appear; the district judge ordered Wakefield to perform work crew and pay $15/month without applying the statutory "manifest hardship" standard or expressly finding ability to pay.
- The superior court remanded for findings; the district court entered findings some of which the appellate courts found contradicted the record (e.g., claiming no evidence of disability, attributing indigency to "life choices").
- The Washington Supreme Court reversed, holding the district court applied the wrong legal standard, failed to consider eligibility for means-tested benefits and the inability to meet basic needs, and that federal law (Social Security anti-attachment) barred ordering payments when SSI is the sole income source.
- The Court remanded with instructions to remit Wakefield’s LFOs and struck several unsupported factual findings.
Issues
| Issue | Wakefield's Argument | Cities' Argument | Held |
|---|---|---|---|
| 1. Whether district court applied correct statutory remission standard under RCW 10.01.160(4) | Court must apply "manifest hardship" test and remit when paying imposes hardship | Payment plan acceptable; Wakefield can make minimal payments | District court erred by not applying "manifest hardship"; remand ordered for remission (court remitted here) |
| 2. Whether court properly considered disabilities, homelessness, and means-tested benefits in ability-to-pay analysis | Eligibility for SSI/food stamps and inability to meet basic needs is strong evidence of indigency; GR 34 guidance applies | Some ability to pay exists; payments appropriate | Court must consider inability to meet basic needs and GR 34 standards; such eligibility is strong evidence of indigency; low token payments may be unjustly punitive |
| 3. Whether ordering payments violates Social Security Act anti-attachment (42 U.S.C. §407) when SSI is sole income | Ordering monthly payments from person whose only income is SSI is an "other legal process" barred by §407 | States may calculate ability to pay including SSI in overall financial picture | Court held federal law bars ordering LFO payments when the defendant's only income is Social Security disability benefits |
| 4. Whether district court findings were supported by substantial evidence | Several findings contradicted record (disability, cause of poverty, bona fide efforts) | Findings reflected judge's view of willfulness and choices | Several key findings struck as unsupported; record showed SSI disability and lack of alternative resources |
Key Cases Cited
- State v. Blazina, 182 Wn.2d 827 (2015) (GR 34 and indigency guidance for LFO ability-to-pay analyses)
- Philpott v. Essex County Welfare Board, 409 U.S. 413 (1973) (Social Security benefits retain protected status from state claims after deposit)
- Bennett v. Arkansas, 485 U.S. 395 (1988) (federal protection of Social Security benefits applies against state attempts to recoup)
- Wash. State Dep’t of Soc. Health Servs. v. Guardianship Estate of Keffeler, 537 U.S. 371 (2003) (definition of "other legal process" under §407)
- In re Lampart, 306 Mich. App. 226 (2014) (state court holding courts may not order LFOs to be paid from SSDI when SSDI is sole income)
- State v. Eaton, 323 Mont. 287 (2004) (Montana Supreme Court: SSDI may not be included in income calculation to require LFO payments)