Egelhoff v. Egelhoff
United States Supreme Court
532 U.S. 141 (2001)
David Egelhoff, Sr. divorced Donna Rae (defendant) and died intestate about two months later, having never changed his ERISA-governed life insurance and pension beneficiary designations naming Donna Rae from during the marriage. After the insurer paid Donna Rae $46,000 as the named beneficiary, David's children from a prior marriage (plaintiffs) sued in Washington state court to recover the proceeds, relying on a state statute automatically revoking a former spouse's beneficiary designation in non-probate assets (including ERISA plans) upon divorce, treating the ex-spouse as having predeceased the participant. The Washington Supreme Court ruled for the children, and Donna Rae sought U.S. Supreme Court review.
Whether ERISA preempts a state statute that automatically invalidates a beneficiary designation in an ERISA-governed plan upon divorce, rather than requiring compliance with the plan's own administrative rules for changing beneficiaries.