Whether ERISA precludes garnishment of 401(k) plan to satisfy restitution order

QUESTIONS PRESENTED 1. Whether the Employee Retirement Income Security Act, pursuant to which retirement plan benefits “may not be assigned or alienated,” 29 U.S.C. § 1056(d)(1), precludes the government from garnishing an individual’s 401(k) plan account to satisfy a restitution order under the Mandatory Victims Restitution Act. 2. Whether a lump-sum distribution from a 401(k) plan account constitutes “earnings” subject to the 25 percent cap on garnishment under the Consumer Credit Protection Act, 15 U.S.C. §§ 1672(a), 1673(a).