United States v. Joyce Ashcraft, 732 F.3d 860

Ashcraft appeals district court decision denying objection to garnishment of disability payments.
District court held Ashcraft's disability payments are not 'earnings' under 15 U.S.C. § 1673(a).
Garnishment was sought in February 2012 in connection with restitution obligations.
Disability benefits come from Amana via Principal Life Insurance Company as part of Ashcraft's compensation.
Court applies de novo review to statutory interpretation and analyzes the Act's plain language.
Court reverses, holding disability payments are 'earnings' and subject to garnishment limits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are disability payments 'earnings' under the Act?	Ashcraft: yes, within the Act's inclusive scope of 'periodic payments'.	Government: no, not 'compensation paid or payable for personal services'.	Yes; disability payments are 'earnings' under the Act.
Do disability payments fit 'compensation paid or payable for personal services'?	Ashcraft: payments are employment-based, replacement income.	Government: payments arise from disability, not personal services.	They are 'compensation paid or payable for personal services' as disability benefits replace past earnings.

Kokoszka v. Belford, 417 U.S. 642 (U.S. Supreme Court, 1974) (earnings limited to periodic payments of compensation)
Planned Parenthood Minn., N.D., S.D. v. Rounds, 686 F.3d 889 (8th Cir. 2012) (statutory interpretation of 'earnings'; plain language guidance)
In re Conway, Bankr. LEXIS 1988 (Bankr. S.D. Ala. 2003) (disability payments treated as earnings in bankruptcy context)
Rousey v. Jacoway, 544 U.S. 320 (U.S. Supreme Court, 2005) (benefit plans include disability benefits as wage substitutes)
United States v. Cunningham, 866 F. Supp. 2d 1050 (S.D. Iowa 2012) (discusses pension payments within garnishment limits)
United States v. DeCay, 620 F.3d 534 (5th Cir. 2010) (interpretation of 'earnings' under the Act across circuits)