Opinion · Supreme Court of the United States

Egelhoff v. Egelhoff Ex Rel. Breiner

121 S. Ct. 1322

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

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 | holding that a Washington state statute that binds ERISA plan administrators to a particular choice of rules for determining beneficiary-status has an impermissible “connection with” ERISA, as the statute “implicates an area of core ERISA concern” | holding that ERISA preempted application of Washington statute in state probate proceedings | recognizing that payment of benefits as “a central mátter of plan administration” | stating that slayer statutes have been adopted by nearly every state and that such statutes have a “long historical pedigree” | finding that ERISA preempted state statute in part because of administrative burdens and potential conflicting legal obligations it created | holding that a Washington state law which automatically revoked designation of spouse as plan beneficiary upon divorce was preempted as applied to ERISA plans because it conflicted with ERISA’s requirement that a plan be administered according to the plan’s terms | noting that the “most recent Supreme Court approach” requires courts to look instead at the purpose of ERISA rather than the overly expansive “relate to” test | emphasizing that ERISA preemption provision is deliberately expansive and designed to establish pension plan regulation as an exclusively federal concern | noting that the Court has “recognized that the term ‘relate to’ cannot be taken ‘to extend to the furthest stretch of its indeterminacy’” | explaining that ERISA’s “expansive” preemption clause covers any state law that “has a connection with or reference to [an ERISA] plan” (quotations omitted) | explaining that ERISA’s “expansive” preemption clause covers any state law that “has a connection with or reference to [an ERISA] plan” (quotations omitted) | holding a Washington statute that revoked a spouse’s designation as a beneficiary upon divorce preempted by ERISA | noting that the Court has “recognized that the term ‘relate to’ cannot be taken ‘to extend to the furthest stretch of its indeterminacy’” | holding a state law that invalidated beneficiary designation upon divoree was preempted, but distinguishing it from "generally applicable laws regulating areas where ERISA has nothing to say" (internal quotation marks omitted) | holding that ERISA preempted a similar Washington state law | stating that the principal goal of Employee Retirement Income Security Act is to provide "a set of standard procedures to guide processing of claims and disbursement of benefits" | declining to decide whether ERISA preempts state statutes forbidding a murdering heir from receiving property as a result of the killing | identifying “the conflict between the plan documents (which require making payments to the named beneficiary) and the statute (which requires making payments to someone else)” | stating that ERISA preempts only those laws that themselves affect employee benefit plans | acknowledging that “[o]ne of the principal goals of ERISA

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309 opinions