Egelhoff v. Egelhoff

Last updated
Egelhoff v. Egelhoff
Seal of the United States Supreme Court.svg
Argued November 8, 2000
Decided March 21, 2001
Full case nameDonna Rae Egelhoff, Petitioner v. Samantha Egelhoff, A Minor, By and Through Her Natural Parent Kate Breiner, and David Egelhoff
Citations532 U.S. 141 ( more )
121 S. Ct. 1322; 149 L. Ed. 2d 264; 2001 U.S. LEXIS 2458; 69 U.S.L.W. 4206; 25 Employee Benefits Cas. (BNA) 2089; 2001 Daily Journal DAR 2861; 2001 Colo. J. C.A.R. 1477; 14 Fla. L. Weekly Fed. S 147
Holding
State statutues having a connection with ERISA plans are superseded by ERISA.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens  · Sandra Day O'Connor
Antonin Scalia  · Anthony Kennedy
David Souter  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Case opinions
MajorityThomas, joined by Rehnquist, O'Connor, Scalia, Kennedy, Souter
ConcurrenceScalia, joined by Ginsburg
DissentBreyer, joined by Stevens
Laws applied
Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C.   § 1001 et seq.

Egelhoff v. Egelhoff, 532 U.S. 141 (2001), is a major decision of the Supreme Court of the United States on federalism, specifically with regards to the preemption powers of federal law over state laws. It sets the precedent that any state statutes having a "connection with" ERISA plans are superseded by ERISA, or any future substantially similar law that takes its place. In essence, this decision is a reaffirmation of the right and ability of the federal government to, at least in some instances, pre-empt state laws.

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions. Each year it agrees to hear about one hundred to one hundred fifty of the more than seven thousand cases that it is asked to review.

Federalism political concept

Federalism is the mixed or compound mode of government, combining a general government with regional governments in a single political system. Its distinctive feature, exemplified in the founding example of modern federalism by the United States of America under the Constitution of 1787, is a relationship of parity between the two levels of government established. It can thus be defined as a form of government in which there is a division of powers between two levels of government of equal status.

In the law of the United States, federal preemption is the invalidation of a U.S. state law that conflicts with federal law.

Contents

Background

Washington resident David A. Egelhoff was married to Donna Rae Egelhoff, and during that time he designated her as the beneficiary of a life insurance policy and pension plan provided by his employer, The Boeing Company. The life insurance policy & pension were governed by the Employee Retirement Income Security Act of 1974 (ERISA), a piece of federal legislation concerning pension and life insurance programs. David Egelhoff subsequently divorced his wife, but did not immediately remove her as a beneficiary. Weeks after the divorce had been finalized, David Egelhoff was killed in a car accident. David Egelhoff's children, from a previous marriage, filed suit against Donna Rae Egelhoff for the benefits (life insurance and pension) from their deceased father. The case was considered under Washington state law wherein the designation of a spouse as beneficiary to "nonprobate asset," a life insurance policy or employee benefit plan, is revoked immediately upon the divorce of the designator and the beneficiary. However, under ERISA, this was not the case, and Donna Rae Egelhoff would be the beneficiary of her late ex-husband's benefits.

Life insurance is a contract between an insurance policy holder and an insurer or assurer, where the insurer promises to pay a designated beneficiary a sum of money in exchange for a premium, upon the death of an insured person. Depending on the contract, other events such as terminal illness or critical illness can also trigger payment. The policy holder typically pays a premium, either regularly or as one lump sum. Other expenses, such as funeral expenses, can also be included in the benefits.

A pension is a fund into which a sum of money is added during an employee's employment years, and from which payments are drawn to support the person's retirement from work in the form of periodic payments. A pension may be a "defined benefit plan" where a fixed sum is paid regularly to a person, or a "defined contribution plan" under which a fixed sum is invested and then becomes available at retirement age. Pensions should not be confused with severance pay; the former is usually paid in regular installments for life after retirement, while the latter is typically paid as a fixed amount after involuntary termination of employment prior to retirement.

Boeing Aerospace and defense manufacturer in the United States

The Boeing Company is an American multinational corporation that designs, manufactures, and sells airplanes, rotorcraft, rockets, satellites, and missiles worldwide. The company also provides leasing and product support services. Boeing is among the largest global aircraft manufacturers; it is the fifth-largest defense contractor in the world based on 2017 revenue, and is the largest exporter in the United States by dollar value. Boeing stock is included in the Dow Jones Industrial Average.

The trial court decided that ERISA pre-empted Washington state law, and granted Donna Rae Egelhoff the benefits she sought. The Washington Court of Appeals reversed this decision, claiming that the federal law did not supersede state law. The Supreme Court of Washington affirmed this decision, citing that, because the Statute did not "refer to" or have a "connection with" an ERISA plan, the state law would be most appropriate. The Supreme Court granted certiorari and heard the case.

Certiorari, often abbreviated cert. in the United States, is a process for seeking judicial review and a writ issued by a court that agrees to review. A certiorari is issued by a superior court, directing an inferior court, tribunal, or other public authority to send the record of a proceeding for review.

Decision

The Supreme Court disagreed with the decision of the Washington State Supreme Court, and instead ruled that this law did, in fact, have a "connection with" an ERISA plan, and was therefore pre-empted by the federal legislation. According to the decision, the criteria used to determine whether or not a state law has a connection with ERISA, "the Court looks both to ERISA’s objectives as a guide to the scope of the state law that Congress understood would survive, as well as to the nature of the state law’s effect on ERISA plans." Further, the Court believed it, "interfere[d] with nationally uniform plan administration." The Court reasoned that this sort of state law was precisely the sort of situation that ERISA sought to remedy in the first place, and ruled that if it were allowed it would effectively render much of ERISA unenforceable.

See also

<i>United States Reports</i> official record of the rulings, orders, case tables, and other proceedings of the Supreme Court of the United States

The United States Reports are the official record of the rulings, orders, case tables, in alphabetical order both by the name of the petitioner and by the name of the respondent, and other proceedings of the Supreme Court of the United States. United States Reports, once printed and bound, are the final version of court opinions and cannot be changed. Opinions of the court in each case are prepended with a headnote prepared by the Reporter of Decisions, and any concurring or dissenting opinions are published sequentially. The Court's Publication Office oversees the binding and publication of the volumes of United States Reports, although the actual printing, binding, and publication are performed by private firms under contract with the United States Government Publishing Office.

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