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MacKey v. Lanier Collection Agency & Service, Inc.
Citations: 343 S.E.2d 492; 178 Ga. App. 467; 1986 Ga. App. LEXIS 2545Docket: 71125
Court: Court of Appeals of Georgia; February 18, 1986; Georgia; State Appellate Court
In Mackey v. Lanier Collection Agency Service, Inc., the Court of Appeals of Georgia addressed a garnishment dispute involving the South Atlantic ILA/Employee Vacation Holiday Fund. The Fund, established under a collective bargaining agreement, provides benefits to longshoremen. Lanier Collection Agency initiated garnishment proceedings after obtaining judgments against individual beneficiaries of the Fund. The trustee of the Fund (appellant) argued that the Fund was exempt from garnishment under OCGA § 18-4-22.1 since the judgments were not for alimony or child support. The trial court ruled in favor of Lanier, determining that the legislative intent behind the Georgia statute aligned with federal law, specifically ERISA, which protects pension plan funds from garnishment but not vacation plan funds. On appeal, the appellant contended that the trial court erred in interpreting OCGA § 18-4-22.1 as not exempting vacation benefits, asserting that the statute's language was clear and did not require interpretation based on its preamble. Conversely, the appellee argued that if the Fund qualified for ERISA protections and was exempt from garnishment, such an exemption would conflict with ERISA's preemption provision. The court noted that ERISA aims to regulate fiduciaries of employee benefit plans and defined "employee pension benefit plans" and "employee welfare benefit plans." It referenced the Supreme Court's decision in Franchise Tax Board v. Construction Laborers Vacation Trust, which classified a vacation trust as an employee welfare benefit plan under ERISA. The court concluded that the Fund is indeed an employee benefit plan under ERISA, thus subject to its regulations, which protect pension plans from involuntary transfers, including garnishment, except for alimony and child support. The Georgia statute, OCGA 18-4-22.1, specifies that pension, retirement, or employee benefit plans governed by ERISA are generally exempt from garnishment, except for alimony or child support judgments. The court interprets this language as indicating the Georgia legislature's intent to protect vacation plans more broadly than ERISA does. The court emphasizes the importance of legislative intent and the statute's plain language, rejecting the trial court's reliance on external sources to determine intent. Furthermore, the court concludes that the Georgia statute is not preempted by ERISA. ERISA's preemption clause is meant to eliminate conflicting state laws affecting employee benefit plans, but the court finds that the garnishment statute does not conflict with federal law or prohibit lawful practices. It notes that the impact of the Georgia statute on ERISA plans is minimal and that state enforcement of money judgments is a valid state concern. Ultimately, the court reverses the trial court's decision, asserting that the Fund cannot be garnished under the state statute.