Opinion · Supreme Court of the United States

Egelhoff v. Egelhoff Ex Rel. Breiner

532 U.S. 141

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
2001-04-02
Topic
general

How later courts describe this case

  • holding that ERISA expressly preempted state statute providing that designation of spouse as beneficiary on nonprobate asset was automatically revoked upon divorce
  • holding that ERISA preempted a Washington statute providing that a divorce automatically revoked a prior designation of a spouse as the beneficiary
  • holding that an ability to opt out of a state law does not save the law from preemption
  • holding that ERISA pre-empted a Washington statute providing that a divorce automatically revoked a prior designation of a spouse as the beneficiary
  • holding that ERISA preempts state statute revoking the designation of a spouse as beneficiary of a pension plan after a divorce
  • holding that ERISA § 1144(a) pre-empted a Washington state statute that would revoke a plan beneficiary’s choice to name a former spouse as a beneficiary
  • concluding that state law that “affects key plan documents such as the [Beneficiary] Designation Form . . . is preempted by ERISA”
  • concluding that the state law was preempted because it governed the payment of benefits

Citator

UpLaw has not yet analyzed Egelhoff v. Egelhoff Ex Rel. Breiner. The absence of a flag is not a finding that it is good law.

Authority status
pending
Cited by
754 opinions
Distinguished
1 times

Headnotes

  1. Employee Benefits & Exec Comp — Express Preemption ERISA's express preemption provision supersedes any and all state laws insofar as they relate to any employee benefit plan covered by ERISA; a state law "relates to" such a plan if it has a connection with or reference to the plan. 532 U.S. at 146–147 (citing 29 U.S.C. § 1144(a); Shaw v. Delta Air Lines, Inc., 463 U.S. 85, 97)
  2. Employee Benefits & Exec Comp — Preemption Analysis In determining whether a state law has a forbidden connection with an ERISA plan, courts look both to the objectives of ERISA as a guide to the scope of state law that Congress understood would survive and to the nature of the state law's effect on ERISA plans, rather than applying an uncritical literalism that would make preemption turn on infinite connections. 532 U.S. at 147 (citing California Div. of Labor Standards Enforcement v. Dillingham Constr., N.A., Inc., 519 U.S. 316, 325; N.Y. State Conference of Blue Cross & Blue Shield Plans v. Travelers Ins. Co., 514 U.S. 645, 655–656)
  3. Employee Benefits & Exec Comp — Preemption of Beneficiary-Designation Statutes A state statute that revokes, upon divorce, a spouse's designation as beneficiary of a nonprobate asset has an impermissible connection with ERISA plans and is expressly preempted, because it binds plan administrators to a particular choice of rules for determining beneficiary status and requires them to pay benefits to beneficiaries chosen by state law rather than to those identified in the plan documents, thereby implicating an area of core ERISA concern. 532 U.S. at 147–148 (construing 29 U.S.C. §§ 1102(b)(4), 1104(a)(1)(D), 1002(8))
  4. Employee Benefits & Exec Comp — Uniform Plan Administration A state law that requires ERISA plan administrators to familiarize themselves with the laws of the various States in order to determine beneficiary status interferes with the congressional goal of nationally uniform plan administration and imposes the very burden that ERISA preemption was intended to avoid; the burden is aggravated by choice-of-law problems confronting administrators where the employer, participant, and former spouse reside in different States. 532 U.S. at 148–150 (citing Fort Halifax Packing Co. v. Coyne, 482 U.S. 1, 9–10; Ingersoll-Rand Co. v. McClendon, 498 U.S. 133, 142)
  5. Employee Benefits & Exec Comp — Opt-Out Provisions A state statute governing ERISA plans is not saved from preemption merely because it operates as a default rule that plan documents may override; the statute still dictates the choices facing ERISA plans, since administrators must either comply with the state's beneficiary-designation scheme or bear the burden of amending the plan to opt out, and must maintain familiarity with the laws of all States to update plans as necessary. 532 U.S. at 150–151
  6. Employee Benefits & Exec Comp — Preemption and Traditional State Regulation Although there is a presumption against preemption in areas of traditional state regulation such as family law, that presumption is overcome where Congress has made clear its desire for preemption, and state family law may be preempted when it conflicts with or relates to ERISA plans. 532 U.S. at 151 (citing Boggs v. Boggs, 520 U.S. 833; Hisquierdo v. Hisquierdo, 439 U.S. 572, 581)