Riley, J.
Case Summary
Appellant-Plaintiff, Ronda Randall (Randall), Personal Representative of the Estate of Julian M. Roache and Personal Representative of the Estate of Joanne F. Roache, beneficiary of the Julian M. Roache Revocable Living Trust, 1 appeals the trial court’s dismissal of her Complaint against Anita J. Woodson (Woodson), individually and in her capacity as the Trustee of the Julian M. Roache Revocable Living Trust.
We affirm.
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Prior to his death, Julian Roache (Julian) was under a legal disability and received benefits from the Social Security Administration (SSA). Woodson was appointed the representative payee of Julian’s SSA benefits and received at least some of those benefits in her capacity as representative payee. On January 19, 2017, Julian died. Randall is the personal representative of Julian’s estate.
On January 23, 2019, Randall, in her capacity as personal representative of Julian’s estate, filed her Complaint against Woodson, raising claims sounding in breach of fiduciary duty, fraud, conversion, and unjust enrichment. Randall alleged that Woodson had engaged in a “continuous pattern” from December 27, 2013, to January 19, 2017, of improperly transferring assets belonging to Julian and to the Julian M. Roache Revocable Trust (the Trust)…
The issue before us is whether Randall’s state law claims are barred by federal law. Pursuant to the Supremacy Clause of our federal Constitution, federal law is supreme in the United States, and “[t]he preemption doctrine invalidates those state laws that interfere with or are contrary to federal law.”…
The Social Security Act (the Act) permits the Commissioner of Social Security to pay a qualified person’s benefits to an appointed representative payee for the qualified person’s “use and benefit.” 42 U.S.C. §§ 1007(a); 1383(a)(2)(A)(ii)(I). The representative payee’s use of those benefits is subject to detailed regulations and reporting requirements. See, e.g., 20 C.F.R. §§ 416.640 (entitled “Use of benefit payments”); 416.625 (entitled “What information must a representative payee report to us?”); and 416.665 (entitled “How does your representative payee account for the use of benefits”, requiring representative payees to provide a written accounting at least once a year). The Act further provides that, if “the Commissioner of Social Security or a court of competent jurisdiction” has determined that a representative payee has misused any benefit paid to the representative payee, the Commissioner shall promptly revoke the designation and shall make payment to the beneficiary or to an alternate representative payee. 42 U.S.C. §§ 1007(a); 1383(a)(2)(A)(iii)….
Randall does not draw our attention to any portion of the Act which specifically and expressly outlines the scope of its preclusive effect, or which expressly provides state courts with concurrent jurisdiction over claims such as hers, and we located none. However, as set forth above, there exists within the Act and federal regulations a comprehensive scheme directed at preventing, identifying, and rectifying the misuse of benefit funds by representative payees. That scheme defines what constitutes misuse of benefits and provides mechanisms within the SSA for determining when misuse has occurred, for the recovery of benefits from the representative payee, and for payment of misused benefits to the beneficiary or an alternate representative payee. We infer from the existence of this extensive body of regulation that this is an instance of “field preclusion” and that Congress intended for the SSA to exercise exclusive authority over the issues of SSA benefit misuse by representative payees and over the recovery of those misused funds. Doherty, 153 N.E.3d at 239. Therefore, this body of federal law preempts state law claims such as Randall’s seeking to recover SSA benefits from a representative payee.
Our conclusion finds support in the fact that several federal district courts have held that no federal private right of action exists against representative payees to recoup misused SSA benefits..
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In addressing this argument, we first observe that the Act does not further define the term “competent jurisdiction”, and Randall does not present us with any relevant authority from either a federal or state court in this or any other jurisdiction concluding that the use of the phrase “court of competent jurisdiction” in the Act confers concurrent subject matter jurisdiction over a state court to entertain claims such as those presented in her Complaint. However, the Act explicitly provides for both administrative and judicial review of the SSA’s initial determinations, including determinations concerning overpayment of benefits and determinations concerning the SSA’s negligence in investigating or monitoring representative payees. 20 C.F.R. §§ 404.902(j), (x) The Act further provides that an individual may obtain review of a final decision of the Commissioner of Social Security by filing a civil action and that “[s]uch action shall be brought in the district court of the United States for the judicial district in which the plaintiff resides[.]” 42 U.S.C. § 405(g) (emphasis added); 20 C.F.R. § 404.981…. Accordingly, we conclude that Randall’s state tort claims against Woodson were preempted by the Act. As a result, in light of the combined effect of the trial court’s dismissal of Randall’s claims related to the Trust’s assets and our holding today, only those of Randall’s claims related to assets which were neither Trust assets nor Julian’s SSA benefits may go forward, if any exist.
CONCLUSION
Based on the foregoing, we conclude that the trial court lacked subject matter jurisdiction over Randall’s claims pertaining to Julian’s SSA benefits and, therefore, that those claims were properly dismissed.
Affirmed.
Bradford, J. and Weissmann, J. concur