# Amicus Curiae Brief — Pressley v. Pressley

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URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386004_1237%3A2

## Record

- **Collection:** Supreme Court brief
- **Document type:** Amicus Curiae Brief
- **Published:** January 1, 1997
- **Citation:** 520 U.S. 1263

## Text

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| Supreme Court, Us .
: ge ee E D i
J AUS 30 t99¢ i
No. 96-176 CLF |
IN THE

Supreme Court of the Gnited States

OCTOBER TERM, 1996

MARY M. PRESSLEY,
Personal Representative for the Estate
of Alvin J. Pressley, Deceased,

Petitioner,
Vv.

METROPOLITAN LIFE INSURANCE COMPANY
AND BARBARA J. PRESSLEY,

Respondents.

On Petition for a Writ of Certiorari to the
United States Court of Appeals
for the Sixth Circuit

Brief of the American Council of Life Insurance
as Amicus Curiae in Support of the Petition

PATRICIA A. DUNN

Of Counsel STEVEN J. MINTZ
PHILLIP E. STANO (Counsel of Record)
AMERICAN COUNCIL OF JONES, DAY, REAVIS &
LIFE INSURANCE POGUE

1001 Pennsylvania Avenue, N.W 1450 G Street, N.W.
Washington, D.C. 20004 Washington, D.C. 20005
(202) 624-2183 (202) 879-3939

Counsel for Amicus Curiae

RAE OR Sten, =

i
QUESTION PRESENTED

Whether, as two federal circuits have held, the language of the
Employee Retirement Income Security Act of 1974 (“ERISA”)
determines the proper beneficiary of ERISA-regulated welfare
benefits, such as life insurance benefits, regardless of any conflict
with state domestic relations law, or whether the beneficiary
Should be determined, as five circuits have Suggested, by
reference to federal common law, which might give state domestic
relations orders precedence over the designated ERISA-plan
beneficiary.

fABLE OF CONTENTS

Page
EE TEM ooo so ok i
RN 5 eS a Os oo ee iv
INTEREST OF THE AMICUS CURIAE ............ l
Derspemeen Aly SUCRE... lS oe SS l
SUMMARY OF ARGUMENT .................. 2
REASONS FOR GRANTING THE PETITION ........ 3

I. THE FEDERAL CIRCUIT COURTS ARE
FUNDAMENTALLY DIVIDED ON WHETHER
ERISA ITSELF OR FEDERAL COMMON
LAW DETERMINES THE BENEFICIARY OF
ERISA-REGULATED WELFARE BENEFITS
WHEN A BENEFICIARY DESIGNATION
CONFLICTS WITH STATE DOMESTIC
erie itn cc By OO Te Si arr 3

Il. THE CURRENT CONFUSION IN THE LAW
UNDERMINES THE PURPOSES OF ERISA,
HAMPERS ERISA PLAN ADMINISTRATION,

AND RESULTS IN NEEDLESS LITIGATION ... 8

NINN ok Sr Sy ges oes ee el 2 11

iV

TABLE OF AUTHORITIES

Page
Case3
Brandon v. Travelers Insurance. Co., 18 F.3d 1321
(Sth Cir. 1994), cert. denied, 115 S. Ct. 732
Ee eC Cee ee AE eto be oe
Equitable Life Assurance Society of the United
States v. Crysler, 66 F.3d 944 (8th Cir. 1995) .... 6, 7, 10
Estate of Altobelli v. IBM Corp., 77 F.3d 78
Ce Ce, Be 5k hE PSC eae See 8S 6,7
Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101
4, So ee oe yee a is ee oS ee ee 3
Fort Halifax Packing Co. v. Coyne, 482 U.S. 1 (1987).... 9
Fox Valley & Vicinity Construction Workers
Pension Fund v. Brown, 897 F.2d 275 (7th Cir.)
(en banc), cert. denied, 498 U.S. 820 (1990) ...... 5.7
Ingersoll-Rand Co. v. McClendon, 498 U.S. 133
ee 2c 6e see cee SR Mh ee ee ce es 8,9, 10
Krishna v. Colgate Palmolive Co., 7 F.3d 11
CE So BR ie ns CREME BOCA ES 4.4.9
Lyman Lumber Co v. Hill, 877 F.2d 692
ee Sa rhb ck 6's 3. 2S MCA Sed wh aS 6,7
McMillan v. Parrott, 913 F.2d 310
SE ea rie eter Gata shane Eee arene 4,9, 10
Metropolitan Life Insurance Co. v. Hanslip,
See ie Pe es RED ik ook a ows oie ween 6, 10
Metropolitan Life Insurance Co. v. Pressley,
ee aes Be Gs NE 6 eo oe es ee wa 3,4
Metropolitan Life Insurance Co. v. Wheaton,
ee a Te is BD ek a a ee oe 10
Mohamed v. Kerr, 53 F.3d 911 (8th Cir.),
cert. denied, 116 S. Ct. 185 (1995) ............ 6, 10
National Automobile Dealers and Associates
Retirement Trust v. Arbeitman, 89 F.3d 496
Ge el SE io ca RSS E A ORO ORAR ReR OO 6

ciate,

Vv

Pilot Life Insurance Co. v. Dedeaux, 481 U.S. 41

OE ev oS 8 Nas CREO Ua he ed Re. 3, 8
Shaw v. Delta Air Lines, Inc., 463 U.S. 85 (1983) ...... qy
Textile Workers Union of America v. Lincoln Mills

of Alabama, 353 U.S. 448 (1957) ............... 3
Statutes
BP Mees ee CO 25 ss oo ae ate es ee es ]
Se a 6 oe 0 53 + hack ke ee 2
SF re EE kat oa hv vee ko a 4
aes a ED 6 6 9b wok wd we eee 3,8
Legislative Materials
H. Rep. No. 533, 93d Cong., 2d Sess., reprinted

SS SSE We tas SU ssn ek Be a bee 8

siieeeiiaiaiai iii

INTEREST OF THE AMICUS CURIAE!

The American Council of Life Insurance (“ACLI”) is the
largest life insurance trade association in the United States,
representing the interests of 580 member life insurance
companies, including respondent Metropolitan Life Insurance
Company. These companies currently underwrite roughly 90.9
percent of the life insurance in force in legal reserve life
insurance companies in the United States.

ACLI member companies frequently serve as ERISA benefit
pian administrators or fiduciaries. ACLI members therefore have
a vital interest in legal questions affecting the interpretation of
ERISA, in promoting uniform and consistent rules of ERISA plan
administration, and in avoiding needless litigation over ERISA
plan issues.

STATEMENT OF THE CASE

Alvin Pressley, deceased, was an employee of General Motors
Corporation in Michigan. During. his employment, he
participated in a company life insurance plan in which the
insurance was provided by respondent Metropolitan Life
Insurance Company (“Met Life”). The plan is an “employee
welfare benefit plan” as defined by the Employee Retirement
Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1002(1)
(1994).?

On March 5, 1979, Alvin Pressley designated his wife,
respondent Barbara Pressley, as beneficiary on his life insurance
plan. On September 7, 1984, however, Alvin Pressley and
Barbara Pressley divorced. The divorce decree entered by the
Michigan state court provided, in pertinent part, that Alvin
Pressley and Barbara Pressley thereafter would own any

' The parties’ letters of consent have been filed with the Clerk pursuant
to Rule 37.2 of this Court.

? As defined in 29 U.S.C. § 1002(3), employee benefit plans are of two
types: Welfare benefit plans provide health, legal, vacation, or other
benefits, § 1002(1), and pension benefit plans provide retirement
income, § 1002(2).

ee ee

2

“insurance policies” “free and clear of any claim thereto by the
other,” and further provided that “any rights of either party in
any policy or contract of life, endowment or annuity insurance of
the other, as beneficiary, are hereby extinguished unless
specifically preserved by this judgment.” Pet. App. 5a-6a.’

Alvin Pressley died on June 10, 1993, without having changed
his designated beneficiary on his insurance plan. Barbara
Pressley then filed a claim with Met Life for the insurance
benefits, and Alvin Pressley’s mother, petitioner Mary Pressley,
also filed a claim for the same benefits with Met Life as Personal
Representative of Alvin Pressley’s estate. On March 30, 1994,
Met Life filed a complaint in interpleader in federal district court
and deposited the life insurance benefits with the court. The
district court granted summary judgment in favor of Barbara
Pressley on the ground that ERISA preempts Michigan domestic
relations law, Pet. App. 14a-18a, and the Sixth Circuit affirmed.
Pet App. 3a-12a.

SUMMARY OF ARGUMENT

This case raises the extent to which ERISA preempts state
domestic relations law. The petition should be granted for two
reasons. First, seven of the federal circuits are starkly and
fundamentally divided over whether ERISA itself or federal
common law, which in turn might incorporate state law,
determines the proper beneficiary of ERISA-regulated employee
welfare benefits, such as life insurance benefits, when the
employee’s designation of a beneficiary conflicts with state
domestic relations law. If ERISA itself provides the rule of
decision, state law has no role and the employee’s designated
beneficiary will receive the benefits; federal common law,

> The Sixth Circuit accepted as an undisputed fact that the divorce
decree was not a qualified domestic relations order (a “QDRO”) of the
type that is expressly exempt from ERISA preemption. Pet. App. 6a;
29 U.S.C. § 1056(d)(3) (1994). For example, the decree apparently did
not specifically identify Alvin Pressley’s insurance plan or name an
“alternate payee.” 29 U.S.C. § 1056(d)(3)(B), (C).

RN ak Poe prune ee

3

however, would in some cases give precedence to state domestic
relations orders over the designated beneficiary. Second, the
confusion in the law that results from this circuit split undermines
the purposes of an important federal statute, hampers ERISA plan
administration, and foments needless litigation.

REASONS FOR GRANTING THE PETITION

I. THE FEDERAL CIRCUIT COURTS ARE
FUNDAMENTALLY DIVIDED ON WHETHER
ERISA ITSELF OR FEDERAL COMMON LAW
DETERMINES THE BENEFICIARY OF ERISA-
REGULATED WELFARE BENEFITS WHEN A
BENEFICIARY DESIGNATION CONFLICTS WITH
STATE DOMESTIC RELATIONS LAW

Section 514(a) of ERISA provides that federal lew shall
supersede all state laws that relate to an ERISA plan. See 29
U.S.C. § 1144(a) (1994). Federal courts almost uniformly hold
that a designation of beneficiaries is related to an ERISA plan,
thus preempting state law. See Metropolitan Life Insurance Co.
v. Pressley, 82 F.3d 126, 129 (6th Cir. 1996) (citing cases).

But the federal circuit courts are starkly divided on the
question that logically follows the general determination of
preemption and is crucial to the parties claiming benefits under an
ERISA-regulated plan: When an employee’s designation of a
beneficiary conflicts with a state domestic relations order, does
ERISA itself determine who is the proper beneficiary, or must the
beneficiary be determined by reference to the federal common law
interpreting ERISA? See Firestone Tire & Rubber Co. v. Bruch,
489 U.S. 101, 110 (1989) (“we have held that courts are to
develop a ‘federal common law of rights and obligations under
ERISA-regulated plans’”) (quoting Pilot Life Insurance Co. v.
Dedeaux, 481 U.S. 41, 56 (1987)). Federal common law, in
turn, may incorporate or be guided by state law. See Textile
Workers Union of America v. Lincoln Mills of Alabama, 353 U.S.
448, 457 (1957).

4

Seven of the federal circuits have faced this question within the
past seven years, and the result is a fundamental split. The
Second and Sixth Circuits hold that ERISA itself determines the
proper beneficiary by reference to the ERISA plan documenis, so
that a divorce settlement has no effect on the decedent’s
designated beneficiary. The Fourth, Fifth, Seventh, Eighth, and
Tenth Circuits hold or suggest that ERISA is silent with respect
to determining the proper beneficiary, so that courts must look to
federal common law for the controlling rules. In some cases,
federal common law would permit a divorce settlement to operate
as a waiver of an ex-spouse’s interest in the decedent’s insurance
plan.

In the instant case, the Sixth Circuit acknowledged that “the
courts of appeals are split regarding the manner in which a
beneficiary is then determined,” Metropolitan Life, 82 F.3d at
129, but then held squarely that “ERISA itself supplies the rule
of law.” Jd. at 130. Because ERISA requires a plan
administrator to act “in accordance with the documents and
instruments governing the plan,” 29 U.S.C. § 1104(a)(1)(D)
(1994), the plan documents always control. The court based its
decision on the reasoning of McMillan v. Parrott, 913 F.2d 310
(6th Cir. 1990), where it held that “This clear statutory command
[29 U.S.C. § 1104(a)(1)(D)], together with the plan provisions,
answer the question; the documents control, and those name [the
divorced spouse].” /d. at 311-312.

The Second Circuit similarly has held that the beneficiary
designation in ERISA plan documents controls. In Krishna v.
Colgate Palmolive Co., 7 F.3d 11 (2d Cir. 1993), the court
reversed a summary judgment on the ground that the district court
should have applied the terms of an ERISA-regulated life
insurance policy rather than New York law. The Second Circuit
differed from the Sixth Circuit’s reasoning by finding that
“ERISA is indeed silent on the matter of which party shall be
deemed beneficiary among disputing claimants,” id. at 14
(internal quotation omitted), but it reached the same conclusion by
holding that, in light of the interest in uniform administration of
ERISA plans, “It would be counterproductive to compel the

5

Policy administrator to look beyond those [plan] designations into
varying state laws regarding wills, trusts and estates, or domestic
relations to determine the proper beneficiaries of Policy
distributions.” Jd. at 16.

In contrast, five other circuits hold or suggest that the language
of ERISA does not resolve who is the proper beneficiary, and
these courts therefore look to federal common law for the rule of
decision. This approach originated in Fox Valley & Vicinity
Construction Workers Pension Fund v. Brown, 897 F.2d 275, 280
(7th Cir.) (en banc), cert. denied, 498 U.S. 820 (1990), where
the Seventh Circuit reasoned that “ERISA is silent on the issue of
what constitutes a proper waiver” of an interest in a pension plan,
thus compelling the court to fashion a rule of federal common
law. Jd. at 280-81. The Seventh Circuit ruled that a divorced
wife effectively waived any interest in her husband’s pension plan
in a state-court divorce decree and thus was not entitled to
payment of his death benefits.

The Fifth Circuit applied the Seventh Circuit’s approach to life
insurance benefits in Brandon v. Travelers Insurance Co., 18
F.3d 1321 (Sth Cir. 1994), cert. denied, 115 S. Ct. 732 (1995).
The Fifth Circuit recognized the division of authority, stating:
“Courts . . . have split as to whether ERISA itself supplies the
rule of law or whether judges must look to federal common law
for the controlling principles.” Jd. at 1325. The Fifth Circuit
rejected the Sixth Circuit’s approach in McMillan and concluded
that “the federal common law approach outlined by the court in
Fox Valley [is] the most persuasive resolution of the issues of this
case.” Jd. at 1326. In Brandon, the federal common law
approach again resulted in a determination that a divorce decree
constituted an effective waiver of the ex-spouse’s interest in the
decedent’s life insurance.‘

* The Fifth Circuit differs from the other circuits that follow the federal
common law approach, however, because the Brandon court selected
that approach not because it found ERISA to be silent, but because
“When courts face a potential conflict between state domestic relations

6

The Fourth Circuit also has noted the circuit split. See Estate
of Altobelli v. IBM Corp., 77 F.3d 78, 81 (4th Cir. 1996). The
Fourth Circuit rejected the Sixth and Second Circuit approach and
“join{ed] the Seventh Circuit in holding as a matter of federal
common law that such a waiver [of ERISA plan insurance
benefits] is to be given full effect.” id. at 82.

Likewise, in the Eighth Circuit “a settlement entered into
pursuant to a judgment of dissolution may divest a former spouse
of beneficiary rights to life insurance proceeds, even when the
beneficiary designation has not been changed before the death of
the insured.” Mohamed v. Kerr, 53 F.3d 911, 914 (8th Cir.),
cert. denied, 116 §. Ct. 185 (1995). The Eighth Circuit reasoned
that it was “compelled to look to federal common law” for this
rule. Id. at 913.°

The Tenth Circuit similarly has suggested that a divorce
settlement can override an ERISA plan beneficiary designation.
See Metropolitan Life Insurance Co. v. Hanslip, 939 F.2d 904,
907 (10th Cir. 1991) (stating that “absent any applicable divorce
decree dictating otherwise,” a former spouse who was the
designated beneficiary was entitled to the decedent’s life insurance
proceeds).

The different approaches adopted by the various federal circuits
are irreconcilable. Either ERISA is silent on the determination of
the proper beneficiary, or it is not. ERISA either provides the
rule for determining the proper beneficiary, or it does not. If

law and federal law, the strong presumption is that state law should be
given precedence[.]” 18 F.3d at 1326.

° Accord, National Automobile Dealers and Associates Retirement Trust
v. Arbeitman, 89 F.3d 496, 500-01 (8th Cir. 1996); Equitable Life
Assurance Society of the United States v. Crysler, 66 F.3d 944, 948 (8th
Cir. 1995) (“29 U.S.C. § 1104(a)(1) . . . does not prescribe how to
resolve conflicting claims that the plan administrator has interpleaded”);
Lyman Lumber Co. v. Hill, 877 F.2d 692, 693 (8th Cir. 1989) (“None
of ERISA’s express provisions addresses the issue presented.”).

7

ERISA does provide the rule of decision by reference to the plan
documents, there can be no role for federal common law.

But plan documents versus federal common law is not the only
division of authority among the federal circuits on the issue
presented by this case. The circuits that follow the federal
common law approach are themselves inconsistent in how they
determine the proper federal common law rule.

To illustrate, the Seventh Circuit in Fox Valley reasoned that
“ERISA is silent on the issue of what constitutes a proper waiver
in this situation, and the existing body of federal common law
interpreting ERISA gives little guidance on this point.” 897 F.2d
at 280. The Seventh Circuit then adopted state law through
federal common law and followed the Illinois rule on the effect of
a divorce decree on the rights of a divorced spouse. See id. at
281. In Equitable Life Assurance Society of the United States v.
Crysler, 66 F.3d 944 (8th Cir. 1995), the Eighth Circuit similarly
adopted a rule of following the relevant state law, holding “that
the federal common law to be applied is (i) a choice-of-state-law
issue, and then (ii) an application of the relevant state law.” Jd.
at 949.

By comparison, a different panel of the Eighth Circuit
fashioned its federal common law rule not by following the law
of the relevant state, Minnesota, but by discerning the “general
rule” across multiple states. Lyman Lumber Co v. Hill, 877 F.2d
692, 693 (8th Cir. 1989). The Fifth Circuit followed Lyman
Lumber Co. “in utilizing a modified state law to breathe life into
the federal common law.” Brandon, 18 F.3d at 1326. And in
yet another variation, the Fourth Circuit apparently does not
consider state law at all, but simply follows the Seventh Circuit
rule announced in Fox Valley as the federal common law rule.
See Estate of Altobelli, 77 F.3d at 81-82.

The state of the law thus presents a classic scenario for review
by this Court: multiple federal circuits in a state of fundamental
conflict over the proper interpretation of an important federal
statute. Only this Court can resolve whether ERISA speaks to or
controls the determination of the proper beneficiary and what

8

role, if any, state law can have when a beneficiary designation
conflicts with a state domestic relations order.

Il. THE CURRENT CONFUSION IN THE LAW
UNDERMINES THE PURPOSES OF ERISA,
HAMPERS ERISA PLAN ADMINISTRATION, AND
RESULTS IN NEEDLESS LITIGATION

By enacting ERISA, Congress intended to subject employer
pension and welfare plans to a uniform body of federal law and
to promote efficiency and simplicity in the administration of
benefit plans.

These purposes appear most obviously in ERISA’s preemption
language, which provides that, with only a few exceptions,
ERISA “shall supersede any and all State laws insofar as they
may now or hereafter relate to any employee benefit plan[.]” 29
U.S.C. § 1144(a). This broad preemption provision is “deliber-
ately expansive, and designed to establish pension plan regulation
as exclusively a federal concern.” Pilot Life Ins. Co. v. Dedeaux,
481 U.S. at 46 (internal quotation omitted). The legislative
history of ERISA similarly makes clear that federal regulation was
intended to “eliminate[] the threat of conflicting or inconsistent
State and local regulation of employee benefit plans.” Jd.
(quoting legislative history). Accord, e.g., Ingersoll-Rand Co. v.
McClendon, 498 U.S. 133, 142 (1990) (preemption “was intended
to ensure that plans and plan sponsors would be subject to a
uniform body of benefits law; the goal was to minimize the
administrative and financial burden of complying with conflicting
directives among States or between States and the Federal
Government”).

ERISA’s legislative history and the decisions of this Court and
the federal circuit courts likewise show that Congress sought to
promote efficiency and simplicity in benefit plan administration.
“The uniformity of decision which [ERISA] is designed to foster
will help administrators, fiduciaries and participants to predict the
legality of proposed actions without the necessity of reference to
varying state laws.” H. Rep. No. 533, 93d Cong., 2d Sess.
(1973), reprinted in 1974 U.S.C.C.A.N. 4639, 4650. See also,

9

e.g., Shaw v. Delta Air Lines, Inc., 463 U.S. 85, 105 n.25
(1983) (ERISA “was meant to minimize this sort of interference
with the administration of employee benefit plans”); McMillan,
913 F.2d at 312 (Congress’ intent was “that ERISA plans be
uniform in their interpretation and simple in their application”);
Krishna, 7 F.3d at 16 (“There is a strong interest in uniform,
uncomplicated administration of ERISA plans, many of which
function in a number of states.”).

The consequence of the current split in federal circuit court
authority is a state of confusion in the law that undermines the
purposes of ERISA. Most obviously, whether a former spouse
will be the proper beneficiary may vary with state domestic
relations law, even where the employer conduct is the same in
every state. “Such an outcome is fundamentally at odds with the
goal of uniformity that Congress sought to implement.”
Ingersoli-Rand, 498 U.S. at 142.

In addition, in cases where an employee divorces and then dies
without having changed his or her beneficiary designation, the
plan administrator must now examine both federal circuit court
law and, at least in several circuits, state domestic relations law
in order to determine the proper beneficiary. But this process
frustrates the statutory goals of efficiency in administration and
certainty in expectations. As this Court has explained, the costs
associated with these inefficiencies might well “lead those
employers with existing plans to reduce benefits, and those
without such plans to refrain from adopting them.” Fort Halifax
Packing Co. v. Coyne, 482 U.S. 1, 11 (1987).

The confusion in the law also works a particular hardship on
ERISA plan administrators, including the life insurance company
members of the ACLI. The benefit plans of large employers like
General Motors Corporation typically are multistate or national in
scope. ACLI member companies must thus track and discern the
law of virtually every state to determine the rule that might apply
to a particular deceased employee. But employers or plan
administrators should not have to “tailor{] plans and employer

10

conduct to the peculiarities of the law of each jurisdiction.”
Ingersoll-Rand, 498 U.S. at 142.

Finally, the uncertainty in the law compels rival claimants to
ERISA plan benefits, in case after case, to sue the plan
administrator or, as in this case, force the administrator to file an
interpleader or declaratory judgment action to determine the
proper beneficiary. Plan administrators must thus waste
resources on legal costs, and plan assets repeatedly are mired in
needless litigation. A clear rule would “avoid[] expensive
litigation as has occurred in the case before us.” McMillan, 913
F.2d at 312 (footnote omitted).

Only this Court can resolve the confusion created by the
federal circuits’ conflicting interpretations of ERISA. Moreover,
the issue presented by this case should be decided now: allowing
it to fester further, after seven circuits have issued conflicting
decisions, wiil only destroy any remaining uniformity of ERISA
plan administration when domestic relations issues arise and
foment additional needless litigation.

® See, e.g., Metropolitan Life Ins. Co. v. Wheaton, 42 F.3d 1080 (7th
Cir. 1994) (interpleader by insurance company); Mohamed v. Kerr,
supra (same); Equitable Life Assurance Co. v. Crysler, supra (same);
McMillan v. Parrot, supra (declaratory judgment); Metropolitan Life
Ins. Co. v. Hanslip, supra (same).

11

CONCLUSION
The petition for writ of certiorari should be granted.
Respectfully submitted,

PATRICIA A. DUNN

Of Counsel STEVEN J. MINTZ
PHILLIP E. STANO (Counsel of Record)
AMERICAN COUNCIL OF JONES, DAY, REAVIS &
LIFE INSURANCE POGUE
1001 Pennsylvania Ave., N.W. 1450 G Street, N.W.
Washington, D.C. 20004 Washington, D.C. 20005
(202) 624-2183 (202) 879-3939

Counsel for Amicus Curiae

August 30, 1996

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386004_1237%3A2. Public record. Not legal advice.