Egelhoff v. Egelhoff Ex Rel. Breiner
The Supreme Court ruled that a federal law governing employee benefit plans overrides a Washington state law that automatically revoked a divorced spouse's status as beneficiary on life insurance and pension plans.
Because the plan documents still listed the ex-wife as beneficiary and federal law requires benefits to be paid according to those documents, she was entitled to the money despite the divorce and the state law designed to protect the children.
“The statute binds ERISA plan administrators to a particular choice of rules for determining beneficiary status.”
Explaining why the state law improperly interferes with how ERISA plans must be run.
How it got here: Washington trial courts ruled for the ex-wife under ERISA; the Washington Court of Appeals reversed for the children; the Washington Supreme Court affirmed that reversal, and the ex-wife sought Supreme Court review.
The Case in Depth
What happened
David Egelhoff named his wife Donna as beneficiary of his employer-provided life insurance and pension plans. The couple divorced in April 1994, and David died about two months later without updating the paperwork. His children from a previous marriage argued that a Washington law automatically canceled Donna's beneficiary status upon divorce, entitling them to the money instead.
The question before the Court
Does a federal retirement-benefits law override a state law that automatically cancels an ex-spouse's status as beneficiary on a life insurance or pension plan after divorce?
The Court's answer
No — a federal law governing employee benefit plans (ERISA) overrides Washington's rule that automatically cancels an ex-spouse's beneficiary status after divorce. The Court held that ERISA's preemption clause wipes out any state law with a forbidden 'connection' to an ERISA plan, and this law had exactly that connection: it forced plan administrators to pay benefits to whoever state law named, instead of following the beneficiary listed in the plan's own paperwork.
The Court also found the law undermined ERISA's goal of letting employers run one uniform benefits system nationwide, since administrators would have to track different state rules and choice-of-law problems. Because Mr. Egelhoff never updated his paperwork after the divorce, his ex-wife remained the beneficiary named in the documents, and federal law required the plans to pay her.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Millions of people who name beneficiaries on employer-sponsored life insurance and pension plans are affected: state 'divorce revokes beneficiary' laws, common across the country, can no longer be applied to these plans. Divorced workers must proactively update their beneficiary forms after divorce, because state law will no longer automatically do it for them, and ex-spouses named on old forms may unexpectedly inherit benefits.
What changes now
The Washington Supreme Court's ruling for the children is reversed, and the case goes back for further proceedings consistent with the Court's holding that the state's automatic-revocation law cannot be applied to plans governed by federal law. This means the ex-wife, still listed as beneficiary in the plan documents, is positioned to receive the disputed insurance and pension proceeds. The decision does not resolve whether similar reasoning applies to state laws blocking killers from inheriting benefits from those they murder.
What this does not decide
The Court expressly declined to decide whether its reasoning also preempts state 'slayer' statutes, which prevent someone who murders a plan participant from collecting benefits as beneficiary. It limited its holding to the specific divorce-revocation statute and traditional preemption analysis, not broader family or probate law generally.
Concurrences and dissents
Concurrence — Justice Scalia
Justice Scalia agreed with the result but wrote separately to argue that ERISA's 'relate to' preemption clause should be read narrowly, as essentially just a pointer to ordinary conflict and field preemption principles. He worried that any broader reading would have no discernible limit and would sweep up every incidental connection to an ERISA plan.
Dissent — Justice Breyer
“Neither is there any direct conflict between the Washington statute and ERISA, for the one nowhere directly contradicts the other.”The dissent's central objection that no real conflict existed between the state law and federal law.
Justice Breyer argued there was no direct conflict between the Washington statute and ERISA because the state law merely filled a gap the plan documents left silent — what happens when a beneficiary designation becomes invalid. He would have applied ordinary conflict and field preemption principles, found no obstacle to ERISA's purposes, and upheld the law given the strong presumption against preempting traditional family-property regulation.
How the Court got there
The legal reasoning, step by step
- The Court applied ERISA's express preemption clause, which wipes out any state law that 'relates to' an employee benefit plan, and asked whether a state law has a forbidden 'connection with' such a plan by looking at ERISA's objectives and the practical effect of the state law on plan administration.
- The Court found the Washington law directly implicated a core area of ERISA concern because it required plan administrators to pay benefits to whoever state law identified, rather than to the beneficiary actually named in the plan documents, conflicting with ERISA's command that plans be administered according to their own terms.
- The Court reasoned that the law also threatened ERISA's goal of letting employers run a single, uniform benefits system nationwide, because administrators would have to learn and track different state rules — including choice-of-law problems when the employer, worker, and ex-spouse lived in different states.
- The Court rejected the argument that the law's opt-out feature saved it from preemption, reasoning that giving administrators only the choice of following the state rule or amending plan documents to avoid it still counts as dictating a choice imposed by state law.
- The Court also rejected the argument that a strong presumption against preempting family law should control, concluding that presumption can be overcome once it is clear Congress intended broad preemption, and left open (without deciding) whether the reasoning would extend to 'slayer' statutes that block killers from inheriting.
Doctrinal impact
Cases affected by this decision
Reaffirms Boggs v. Boggs (520 U.S. 833)
Cited as prior authority for preempting state family law, community property rules, that conflicted with ERISA plan terms.