Townsel v. DISH Network, LLC

Dist. Ct. did not err in dismissing for failure to state cause of action plaintiff's lawsuit alleging that defendant violated anti-assignment provisions contained in section 407(a) of Social Security Act when defendant collected satellite dish termination fee from plaintiff's debit card that had been funded with plaintiff's Social Security benefits. Merchants do not violate section 407(a) when they allow Social Security recipients to pay for goods and services by using debit or credit cards, and Ct. rejected plaintiff's argument that use of debit card became forbidden assignment of Social Security benefits when plaintiff authorized use of debit card in advance of her debt.