Kennedy v. Plan Administrator for DuPont Savings and Investment Plan
United States Supreme Court
555 U.S. 285 (2009)
William Kennedy designated his wife Liv as beneficiary of his ERISA-governed savings plan with DuPont; their divorce decree divested Liv of any interest in William's pension plans, but William never executed any plan document removing Liv as beneficiary or naming someone else, and Liv never submitted a formal disclaimer of benefits. After William's death, Kari Kennedy (plaintiff), as estate executrix, asked DuPont to pay the plan funds to the estate, but DuPont instead paid Liv as the beneficiary named on the plan's own form. Kari sued, arguing the divorce decree constituted a federal common law waiver of Liv's benefits; the district court ordered payment to the estate, but the Fifth Circuit reversed, finding Liv's waiver would itself be an improper assignment or alienation of plan benefits under ERISA.
Whether the administrator of an ERISA employee pension benefit plan must rely solely on the plan documents in determining the plan's beneficiary.