Egelhoff v. Egelhoff Ex Rel. Breiner
Federal law blocks Washington’s automatic divorce revocation rule from changing ERISA plan beneficiaries, holding plan documents control benefit payments and easing administrators’ need to follow fifty different state rules.
Holding
The Court held that ERISA preempts Washington’s statute that automatically revoked an ex‑spouse’s beneficiary designation, so ERISA-plan documents, not state default rules, govern who receives plan benefits.
Real-world impact
- Prevents state divorce-revocation rules from changing ERISA plan beneficiaries.
- Makes plan documents the primary source for deciding benefit recipients.
- Reduces administrators’ need to apply different state rules to ERISA plans.
Topics
Summary
Background
A Washington law said that when people divorce, any prior designation naming a spouse as beneficiary of nonprobate assets (like life insurance or pension benefits) is automatically revoked. David Egelhoff had named his then-wife as beneficiary of an ERISA-covered life insurance policy and pension. After their divorce he died; his children sued under the Washington statute to recover benefits that went to the ex-wife.
Reasoning
The Court asked whether ERISA, the federal law that governs many workplace benefit plans, overrides that Washington rule when the asset is part of an ERISA plan. The majority said yes. It found the state rule interfered with central ERISA goals: plans must be administered according to their documents and administrators must be able to use uniform national rules. The Court emphasized that the Washington statute could force administrators to pay according to state law rather than the written plan, creating burdens and inconsistent results across States.
Real world impact
As a result, ERISA-plan documents now control benefit payments even if a State’s default rule would automatically revoke an ex‑spouse’s designation. Employers and plan administrators should rely on plan forms and may need to change plan language to address state variations. The Court reversed the Washington high court and sent the case back for further proceedings consistent with this ruling.
Dissents or concurrances
A concurrence agreed the state law conflicts with ERISA. A dissent argued the state rule is a background default that fills gaps in plan silence and that preemption should not bar such traditional family-law rules.
Opinions in this case
- 1.Opinion 118416
- 2.Opinion 9434061
- 3.Opinion 9434060
- 4.Opinion 9434062
Questions, answered
Ask questions about the entire case, including all opinions (majority, concurrences, dissents). Try:
- “What was the Court's main decision and reasoning?”
- “How did the dissenting opinions differ from the majority?”
- “What are the practical implications of this ruling?”