Egelhoff v. Egelhoff

532 U.S. 141 (2001)

Facts

D was married to David who worked at Boeing. Boeing provided him with a life insurance policy and a pension plan. Both plans were governed by ERISA. David designated his wife as the beneficiary under both. They divorced, and two months later David died in an auto accident. At that time the mother remained the listed beneficiary under both the life insurance policy and the pension plan. The life insurance proceeds, of $46,000, were paid to her. Ps, David's children from a prior marriage, are his statutory heirs under state law. Ps sued to recover the life insurance proceeds. State law holds that if a marriage is dissolved or invalidated, a provision made prior to that event that relates to the payment or transfer at death of the decedent's interest in a nonprobate asset in favor of or granting an interest or power to the decedent's former spouse is revoked. A “nonprobate asset” includes “a life insurance policy, employee benefit plan, annuity or similar contract, or individual retirement account.” Ps argued that D was disqualified as a beneficiary, and in the absence of a qualified named beneficiary, the proceeds would pass to them as David's heirs. Ps also sued to recover the pension plan benefits under the same state law. The trial courts held that the plan must be administered in accordance” with ERISA, granted summary judgment to D in both cases. The Washington Court of Appeals reversed. The Supreme Court of Washington affirmed. It emphasized that the statute “does not alter the nature of the plan itself, the administrator's fiduciary duties, or the requirements for plan administration.” The Supreme Court granted certiorari.