stating that a 'principal goal[] of ERISA' was 'to enable employers "to establish a uniform administrative scheme, which provides a set of standard procedures to guide processing of claims and disbursement of benefits" ' and that '[u]niformity is impossible ... if plans are subject to different legal obligations in different States' (quoting Fort Halifax Packing Co. v. Coyne, 482 U.S. 1, 9 , 107 S.Ct. 2211 , 96 L.Ed.2d 1 (1987))
How later courts described this case
- stating that a 'principal goal[] of ERISA' was 'to enable employers "to establish a uniform administrative scheme, which provides a set of standard procedures to guide processing of claims and disbursement of benefits" ' and that '[u]niformity is impossible ... if plans are subject to different legal obligations in different States' (quoting Fort Halifax Packing Co. v. Coyne, 482 U.S. 1, 9 , 107 S.Ct. 2211 , 96 L.Ed.2d 1 (1987))
- holding that state law that removed named beneficiaryspouse from former spouse’s life insurance policy upon divorcewas preemptedbecause “[t]his ‘tailoring of plans and employer conduct to the peculiarities of the law of each jurisdiction’ is exactly the burden ERISA seeks to eliminate” (quoting Ingersoll-Rand Co. v. McClendon, 498 U.S. 133, 142 (1990))
- holding that a state statute providing that a beneficiary designation is automatically revoked on divorce was preempted because it bound “plan administrators to a particular choice of rules for determining beneficiary status” and thus “govern[ed] the payment of benefits, a central matter of plan administration”
- holding the state statute “directly conflicts with ERISA’s requirements that plans be administered, and benefits be paid, inaccordance with plan documents” because the statute requires administrators to look outside the plan to divorce orders to determine who is entitled to benefits
Written by the judges who cited it.
Distinguished
Distinguished by In re Estate of Sauers, 613 Pa. 186 (2011)
Accordingly, we disagree with Administrator and the courts below that, because of the prior restraint clause, the instant appeal is distinguishable from the preemption findings of Egelhoff.
Distinguished by Magellan Health Serv. v. Highmark Life Ins., 749 N.W.2d 705 (2008)
According to Magellan and Wellmark, Egelhoff is distinguishable from the present case because the state statute interfered with the relationship between an ERISA plan and a plan beneficiary and with national uniform administration of ERISA.
The opinion
Justice Scaua,
with whom Justice Ginsburg joins,
concurring.
I join the opinion of the Court, since I believe that the "relate to” pre-emptive provision of the Employee Retirement Income Security Act of 1974 (ERISA) is assuredly triggered by a state law that contradicts ERISA. As the Court notes, "the statute at issue here directly conflicts with ERISA’s requirements that plans be administered, and benefits be paid, in accordance with plan documents.” Ante, at 150. I remain unsure (as I think the lower courts and everyone else will be) as to what else triggers the "relate to” pro *153 vision, which — if it is interpreted to be anything other than a reference to our established jurisprudence concerning conflict and field pre-emption — has no discernible content that would not pick up every ripple in the pond, producing a result “that no sensible person could have intended.” California Div. of Labor Standards Enforcement v. Dillingham Constr., N. A., Inc., 519 U. S. 316, 386 (1997) (Scalia, J., concurring). I persist in the view that we can bring some coherence to this area, and can give the statute both a plausible and precise content, only by interpreting the “relate to” clause as a reference to our ordinary pre-emption jurisprudence. See ibid.