Hillman v. Maretta
The Supreme Court ruled that federal law controls who gets to keep a deceased federal employee's group life insurance money, striking down a Virginia law that let a widow sue her husband's ex-wife to recover proceeds paid to the ex-wife as the still-named beneficiary.
The decision means that under the federal government's life insurance program, whoever an employee formally names as beneficiary keeps the money, even if that designation seems outdated or contrary to what the employee probably would have wanted after a divorce and remarriage.
“Section D interferes with Congress’ scheme, because it directs that the proceeds actually “belong” to someone other than the named beneficiary by creating a cause of action for their recovery by a third party.”
The Court's core reasoning for why Virginia's law conflicts with the federal insurance law.
How it got here: A Virginia trial court ruled for Hillman; the Virginia Supreme Court reversed, finding the state law preempted; Hillman then sought review in the U.S. Supreme Court.
The Case in Depth
What happened
Warren Hillman named his then-wife, Judy Maretta, as the beneficiary of his federal group life insurance policy. They later divorced, and Warren remarried Jacqueline Hillman but never changed his beneficiary paperwork. When Warren died, Maretta, still the listed beneficiary, collected the insurance proceeds. Jacqueline Hillman then sued Maretta under a Virginia law making a former spouse liable to pay over such proceeds to whoever otherwise would have received them.
The question before the Court
When a federal employee died without ever updating his life-insurance beneficiary after divorcing and remarrying, could Virginia law force his ex-wife to hand the insurance money over to his widow?
The Court's answer
No — the Supreme Court ruled that federal law controls who keeps the money, and Virginia's law had to give way. Under the federal program covering government workers' life insurance, benefits go first to whoever the employee formally names in writing as beneficiary, and that right "cannot be waived or restricted" by anything else, including a later divorce or remarriage the employee never got around to reflecting in the paperwork.
Virginia's law would have let the widow sue the ex-wife afterward to recover the money, which the Court said directly undercut the federal guarantee that the named beneficiary actually gets to keep the proceeds. Because Congress built a specific, narrow system for redirecting the money (only through paperwork filed before death), the Court held states cannot create their own after-the-fact workarounds.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Millions of federal workers carry this life insurance, and the ruling means their formal, written beneficiary designation is what counts — not a later marriage, a will, or a state law meant to update outcomes automatically. People going through divorce or remarriage must actively update their federal insurance paperwork, because states cannot step in afterward to redirect the money.
What changes now
This is a final merits ruling, not a remand for further fact-finding. The Virginia Supreme Court's judgment favoring the ex-wife is affirmed, so she keeps the insurance proceeds. Other states with similar laws letting third parties recover federal life-insurance proceeds from a named beneficiary will need to treat those laws as unenforceable against this federal insurance program.
What this does not decide
The Court decided only that Virginia's law conflicted with the federal law's purposes; it did not decide whether the same result would follow under FEGLIA's separate express-preemption clause. Justice Alito's concurrence also flags that the majority did not need to decide whether a beneficiary could keep the money even against an insured's clearly expressed contrary wishes in a later will.
Concurrences and dissents
Concurrence — Justice Thomas
Justice Thomas agreed the Virginia law is preempted but rejected the majority's 'purposes and objectives' approach as an illegitimate basis for striking down state law. He argued courts should look only at whether the ordinary meaning of the federal and state laws directly conflict, and found that Virginia's law conflicts with the federal law's plain text because it strips the named beneficiary of any real right to keep the money.
Concurrence — Justice Alito
Justice Alito agreed with the outcome but would have adopted a narrower rule: state law is preempted only when it overrides an insured's actual, clearly expressed choice of beneficiary. He criticized the majority for going further than necessary, suggesting it would let a named beneficiary keep the money even if the employee had later and indisputably expressed a contrary wish, a question he thought did not need to be resolved here.
How the Court got there
The legal reasoning, step by step
- The Court applied conflict preemption principles, asking whether Virginia's law 'stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress' — a test used when a state law undercuts a federal law's goals even without directly contradicting its text.
- Relying on two earlier cases interpreting similar federal insurance statutes, Wissner v. Wissner and Ridgway v. Ridgway, the Court found that federal life-insurance laws are meant to guarantee that a named beneficiary actually receives and keeps the proceeds, not merely to help the government process payments efficiently.
- Because the federal statute here uses language nearly identical to those earlier laws, promising that proceeds go first to whoever the employee names in writing and stating that this right 'cannot be waived or restricted,' the Court treated protecting the named beneficiary's exclusive right to the money as the law's central purpose.
- The Court held Virginia's law defeated that purpose because it let a third party sue the named beneficiary after the fact and take the money away, effectively substituting a different person for the one the employee had actually chosen.
- The Court also pointed to a narrow federal provision letting divorce decrees redirect proceeds only if filed with the government before the employee's death, reasoning that letting states create additional after-the-fact workarounds would swallow that narrow, carefully limited exception.
Doctrinal impact
Cases affected by this decision
Reaffirms Wissner v. Wissner (338 U. S. 655)
The Court relied on Wissner's rule that federal insurance proceeds belong to the named beneficiary and no other.
Reaffirms Ridgway v. Ridgway (454 U. S. 46)
The Court treated Ridgway as controlling precedent extending Wissner's rule to a similar federal insurance statute.