In re Marriage of Stephenson & Papineau

When Gregory Papineau and Jeri Stephenson divorced, Papineau was ordered to pay monthly child support. In 2010, Papineau became disabled and applied for social security disability insurance (SSDI) benefits for himself and his dependents. In 2012, the Social Security Administration began providing those benefits. Papineau subsequently filed a motion to modify his child support obligation, asking that he be reimbursed or receive a credit for past child-support payments. Specifically, Papineau argued that his children received duplicative payments, both of which satisfied his child support obligations for the period between his application for and the approval of the SSDI derivative benefits. Both the district court and the Court of Appeals determined that Papineau was not entitled to a credit, a reimbursement, or an offset. The Supreme Court reversed, holding (1) a district court may grant a credit to a child-support obligor who is current on child support when a lump-sum payment of accumulated SSDI derivative benefits duplicates the obligor’s support payment, and that credit may be used to offset other support obligations imposed on the obligor; (2) alternatively, a district court may fashion some other remedy permitted under applicable federal statutes and regulations; and (3) because the district court did not recognize the extent of its discretionary powers, this case must be remanded. View "In re Marriage of Stephenson & Papineau" on Justia Law