Whether federal law protecting veterans' disability benefits preempts state court enforcement mechanisms that effectively require surrendering those protected benefits to satisfy spousal support obligations

1, Whether the Supremacy Clause and 38 U.S.C. § 5301(a) prohibit a state court from enforcing spousal support through contempt, garnishment, or equivalent coercive mechanisms when compliance is impossible without surrendering federally protected VA disability compensation. 2. Whether due process permits enforcement measures where the obligor lacks any lawful means of compliance other than the use of federally protected benefits. IV. PROCEDURAL HISTORY Applicant is a disabled veteran whose VA disability compensation is protected from attachment, levy, or other legal process under 38 U.S.C. § 5301(a). Applicant previously sought discretionary review in the Supreme Court of Virginia, which declined review. Subsequent enforcement proceedings have continued notwithstanding unresolved federal questions. In later enforcement proceedings, the circuit court entered a contempt order imposing a suspended sentence of incarceration. Applicant purged that contempt by tendering a $25,000 payment, funded in substantial part through VA disability compensation. That contempt order remains on appeal. On December 1, 2025, the circuit court entered a further enforcement order authorizing garnishment of Applicant’s remaining non-exempt income, setting new compliance deadlines, and preserving authority to activate the previously suspended incarceration. (App. A) While an emergency stay application was pending in the Supreme Court of Virginia in connection with the ongoing contempt appeal (SCV Record No. 250845), Applicant submitted the December 1, 2025 enforcement order as supplemental authority. At that time, the Supreme Court of Virginia was the appropriate court to consider interim relief. Notwithstanding that submission, emergency relief was denied. (App. E) Following entry of the December 1, 2025 enforcement order, Applicant timely noted an appeal from that order and simultaneously sought emergency stay relief in the Court of Appeals of Virginia on December 8, 2025 (VCOA Record No. 2108-25-4). No ruling has issued, and no stay is presently in effect. (Apps. B-C) V. WHY INTERIM RELIEF FROM THIS COURT IS WARRANTED NOW Although state appellate proceedings remain pending, interim relief from this Court is warranted because no stay is presently in effect and continued enforcement of the December 1, 2025 order threatens irreparable impairment of federal statutory and constitutional protections. Applicant has sought emergency stay relief in the appropriate state courts at each procedural stage, and no ruling has issued. Absent temporary intervention, the state trial court’s enforcement mechanisms will compel compliance through garnishment or incarceration, effectively nullifying federal protections afforded under 38 U.S.C. § 5301(a) before those protections may be meaningfully reviewed. Once enforced, the resulting loss of liberty and compelled surrender of federally protected benefits 3 cannot be undone, and subsequent appella