Estate of Easterday Appeal of: Easterday
171 A.3d 911
| Pa. Super. Ct. | 2017Background
- Michael Easterday (decedent) died intestate on Sept. 21, 2014; survived by wife Colleen and children; Matthew appointed administrator.
- Parties executed a postnuptial agreement (PNA) on Dec. 5, 2013 that waived each spouse’s rights to the other’s pensions/retirement benefits and stated the PNA would remain in effect absent written modification.
- Colleen had filed for divorce (Aug. 13, 2013); decedent signed an affidavit of consent on Nov. 30, 2013, but the affidavit was not filed until Jan. 14, 2014 (outside the 30‑day execution window in Pa.R.C.P. 1920.42(b)). Colleen later withdrew the divorce after decedent’s death.
- Decedent named Colleen as beneficiary of a life insurance policy and as survivor beneficiary on his FedEx (ERISA) pension plan; after his death Colleen received insurance and pension proceeds.
- Administrator (Matthew/Estate) sued to recover pension proceeds (under the PNA) and to invalidate the insurance beneficiary designation under 20 Pa.C.S. § 6111.2 (pending divorce with grounds established at death).
- Orphans’ Court awarded pension proceeds to the Estate (enforcing the PNA) but awarded life insurance proceeds to Colleen; both parties appealed. The Superior Court affirms.
Issues
| Issue | Estate’s Argument | Colleen’s Argument | Held |
|---|---|---|---|
| Whether Tosi v. Kizis / practice of treating a withdrawn divorce as never filed controls here and bars application of 20 Pa.C.S. § 6111.2 to invalidate beneficiary designation | Tosi should not apply; §6111.2 applies if grounds were established at death and thus beneficiary designation is ineffective | Orphans’ Court properly followed Tosi and treated withdrawal as negating the divorce, so §6111.2 did not apply | Court declines to apply Tosi; instead looks to whether grounds were established and whether §6111.2 applies (Tosi superseded by Pa.R.C.P. 1920.17) |
| Whether decedent’s affidavit (filed more than 30 days after execution) established grounds for divorce under 23 Pa.C.S. § 3323(g), triggering §6111.2 | Untimely filing still establishes grounds; Rule 1920.42 timing is procedural and need not defeat §3323(g) | Affidavit was stale and invalid under Rule 1920.42(b); no grounds were established | Affidavit was stale; because decedent was notified to re‑execute and failed to do so, grounds were not established and §6111.2 does not apply |
| Entitlement to life insurance proceeds (does §6111.2 render spousal designation ineffective) | If grounds were established, §6111.2 would invalidate the spousal designation and proceeds belong to estate | Because grounds were not established, §6111.2 does not apply and Colleen as named beneficiary keeps insurance proceeds | Held for Colleen: §6111.2 inapplicable (no grounds established), so insurance payable to named beneficiary |
| Enforceability of PNA waiver of pension rights and effect of ERISA (can Colleen keep ERISA pension despite PNA) | PNA clearly and unambiguously waived Colleen’s rights to Decedent’s pension; Estate can recover proceeds from Colleen under state contract law even if ERISA plan paid her | Decedent intentionally named Colleen irrevocable survivor; ERISA preempts state law and plan administrator must pay the named beneficiary; PNA cannot defeat ERISA distribution | Held for Estate: PNA waiver is valid and enforceable; ERISA does not preclude the Estate from recovering pension benefits from Colleen after plan paid them to her (plan administrator must follow plan, but estate can pursue recovery) |
Key Cases Cited
- Tosi v. Kizis, 85 A.3d 585 (Pa. Super. 2014) (addressed effect of discontinuance after death and interplay of divorce continuation and economic claims)
- Egelhoff v. Egelhoff ex rel. Breiner, 532 U.S. 141 (2001) (state statutes revoking beneficiary designations on divorce are preempted as applied to ERISA‑governed plans)
- Kennedy v. Plan Adm'r for DuPont Sav. & Inv. Plan, 555 U.S. 285 (2009) (ERISA requires plan administrators to follow plan documents and named beneficiary designations)
- Estate of Kensinger v. URL Pharma, 674 F.3d 131 (3d Cir. 2012) (estate may recover plan funds from a beneficiary who received them despite a prior waiver)
- Layne v. Layne, 659 A.2d 1048 (Pa. Super. 1995) (spousal waiver of pension rights in a property‑settlement agreement can be enforceable)