NJSBA Family Law Section

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  • 1.  Child's benefits for child of a parent on social security disability

    Posted 02-03-2015 10:45 AM

    Colleagues -

    Can anyone point me to the applicable regulation for who is entitled to receive the benefit paid for the minor child of a disabled person who is on Social Security, where the child does not live full time with the disabled parent? ------------------------------
    C. Megan Oltman Esq.
    Princeton NJ
    (609)947-0784
    ------------------------------



  • 2.  RE: Child's benefits for child of a parent on social security disability

    Posted 02-03-2015 11:06 AM
    It is well established that these
    previously-calculated, non-means-tested benefits already " belong to the child," the intended recipient. See: Potter v.
    Potter, 169 N.J. Super. 140 (App. Div. 1979); Sheren v. Moseley,
    322 N.J. Super. 338 (App. Div. 1999); Diehl v. Diehl, 389 N.J.
    Super. 443 (App. Div. 2006); Labrosciano v. Labrosciano, XXX N.J.
    Super. XXX (Approved for Publication, copy attached hereto pursuant to R.
    1:36-3.) "SSD payments are a substitute for earned income and are thereby
    non-means-tested." Burns v. Edwards,
    367 N.J.Super. 29 (App. Div. 2004).
    Likewise, the Plaintiff is the intended recipient of her share of the
    SSD derivative benefits.

    "The
    benefits are paid to a parent only because the benefits cannot be entrusted to
    a minor child. As a result, the benefits
    should be paid to the parent better situated to use them to support the children. That parent is the custodial parent." Labrosciano, supra, XXX N.J.
    Super. at 13. These
    "benefits are intended to meet current needs." Sheren, supra, 322
    N.J. Super. at 343-344. The
    Diehl Court held that: "a non-custodial
    parent is not entitled to a credit
    for SSD benefits paid for a period before divorce when the non-custodial parent
    had no court-ordered support obligation." Diehl, supra, 398 N.J.Super
    at 450-451.


    "New
    Jersey has a strong public policy requiring parents to support their
    children. Daly v. Daly, 21 N.J.
    599 (1956). One of the fundamental concepts
    in American society is that parents have a moral obligation to support their
    children. (See Dunbar v. Dunbar,
    190 U.S. 340, 351, 23 S.Ct. 757, 761 (1903)). This obligation has become so self-evident
    that the Office of the Inspector General at the Social Security Administration
    considers it a crime to convert or waste benefits intended for the support of a
    child under 42 U.S.C.A. 1320a-7b, which provides, in pertinent part,
    that an individual will be guilty of a crime for "(a) Making or causing to be
    made false statements or representations." The statute provides that any
    person:

    (3)
    having knowledge of the occurrence of any event affecting (A) his initial or
    continued right to any such
    benefit or payment, or (B) the initial or continued right to any such benefit or payment of any other individual in
    whose behalf he has applied for or is receiving
    such benefit or payment, conceals or fails to disclose such event with an
    intent fraudulently to secure such
    benefit or payment either in a greater amount or quantity than is due or when no such benefit or
    payment is authorized,



















    (4)
    having made application to receive any such benefit or payment for the use and benefit of another and having received
    it, knowingly and willfully converts such benefit or payment or any part thereof to a use other than for the use
    and benefit of such other person…


    Andrew A. Bestafka, Esq.


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