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Egelhoff v. Egelhoff | 532 U.S. 141 (2001)

Spouses frequently designate each other as beneficiaries on life-insurance policies and retirement accounts. But what happens if spouses divorce and one of them dies without changing his or her beneficiary designations? Several states have adopted statutes that revoke beneficiary designations in favor of a spouse upon divorce. In Egelhoff versus Egelhoff, the United States Supreme Court explored the intersection of such state statutes and the federal Employee Retirement Income Security Act of 1974, known as ERISA.

While Donna and David Egelhoff were married, David designated Donna as the beneficiary of his life-insurance policy and pension plan, both governed by ERISA. The Egelhoffs subsequently divorced, and David died intestate only two months later. Upon David’s death, Donna, as David’s designated beneficiary, received the proceeds from his life-insurance policy and retirement plan.

David’s son and daughter from a previous marriage filed two suits, one to recover proceeds from David’s life-insurance policy and another to recover proceeds from his retirement plan. The children relied on a Washington statute that automatically revoked the designation of a spouse as a beneficiary on a nonprobate asset upon divorce. The children argued that because David’s beneficiary designations were invalid under state law, the children, as David’s statutory heirs, were the rightful recipients of the proceeds from his life-insurance policy and retirement plan. Donna responded that the Washington statute was preempted by ERISA, and therefore David’s beneficiary designations remained valid.

The trial courts granted summary judgment in favor of Donna, holding that ERISA governed the distribution of proceeds in both cases. The Washington Court of Appeals consolidated the cases and reversed. The Washington Supreme Court affirmed the reversal, and the United States Supreme Court granted cert.

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