Egelhoff v. Egelhoff case brief

Egelhoff v. Egelhoff case brief summary
532 U.S. 141 (2001)

CASE SYNOPSIS

Petitioner ex-wife's petition for writ of certiorari to the Supreme Court of Washington was granted in a case regarding whether the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C.S. § 1001 et seq., pre-empted a state statute involving the effect of divorce on life insurance policy and pension plan proceeds, Wash. Rev. Code § 11.07.010(2)(a) (1994).

CASE FACTS
While petitioner was married to the decedent, the decedent designated petitioner as the beneficiary under a life insurance policy and a pension plan, which were provided by the decedent's employer and governed by ERISA. Two months after petitioner and the decedent divorced, the decedent died intestate. Respondents, decedent's children by a previous marriage, sued petitioner in state court to recover the life insurance and pension plan proceeds based upon a state statute providing that the designation of a spouse as the beneficiary of a nonprobate asset was revoked automatically upon divorce. The state supreme court ruled in favor of respondents.

DISCUSSION

• On certiorari, the Court reversed the judgment. 
• The Court determined that ERISA expressly pre-empted the statute to the extent it applied to ERISA plans because the statute directly conflicted with ERISA's requirements that plans be administered, and benefits be paid, in accordance with plan documents. 
• In addition, the state statute interfered with nationally uniform plan administration, one of the principal goals of ERISA.

CONCLUSION
State court judgment was reversed because federal law pre-empted the relevant state statute.

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