Justice González, writing in dissent in State v. Catling, No. 95794-1, 2018 WL 8053861 (Wash. Apr. 18, 2019), cited Ms. Tarra Simmons’s Forum Essay, Transcending the Stigma of a Criminal Record: A Proposal to Reform State Bar Character and Fitness Evaluations. The Social Security Act’s antiattachment provision, 42 U.S.C. § 407(a) (2018), prohibits Social Security Disability Income (SSDI) from being “subject to . . . legal process” for the payment of a debt. Justice González argued that § 407(a) prohibits courts from imposing mandatory legal financial obligations (LFOs)—e.g., victims’ compensation assessments, criminal filing fees, and DNA collection fees—on a person whose sole source of income is SSDI. Catling, 2018 WL 8053861, at *7. He cited Ms. Simmons’s Essay to assert that unpayable LFOs significantly burden a formerly justice-involved individual. Id. For example, in Washington, unpaid LFOs prevent a person from vacating his criminal record and from receiving permanent restoration of his right to vote. Id. The slip opinion for Catling is available here.