Regarding the Lockhart v. U.S. case currently on the U.S. Supreme Court's docket, the relatively limited (but significant) issue before the court is whether a 10-year limit (established under the 1982 Debt Collection Act) on the federal government's ability to seize Social Security benefits to pay for federally guaranteed student loans has been eclipsed by Higher Education Act 1991 amendments eliminating any and all previously-established limits on the amount of time within which the government must pursue the collection of student loan debts. Arguably the Supreme Court's decision will have little impact on a student's decision regarding whether or when to consolidate existing student loans. The Court's ruling (either upholding or eliminating the 10-year limit) will apply to student loans regardless of whether they are multiple individual loans or a single consolidated loan. Under consolidation, most students extend the repayment period of their loans, resulting in the federal government gaining an extended window in which to attach Social Security benefits. However, this may or may not be a significant factor for any particular borrower depending (for example) on the extent to which an individual expects to be reliant upon Social Security benefits. At any rate, the outcome of the Lockhart case will be a more peripheral issue for most borrowers considering consolidation, in comparison to factors such as repayment period, interest rates, and the modification of loan terms resulting from the termination of existing promissory notes and the creation of a new consolidation promissory note with new and different terms.