Hillman v. Maretta
133 S. Ct. 1943
| SCOTUS | 2013Background
- FEGLIA provides a government-administered life-insurance program with an order of precedence that pays the designated beneficiary first, via a written designation filed with the government.
- Virginia §20-111.1(A) revokes a beneficiary designation in a contract that pays a death benefit to a former spouse after divorce or annulment.
- Virginia §20-111.1(D) creates a cause of action whereby a former spouse can recover the proceeds if Section A is pre-empted.
- Warren Hillman named Judy Maretta as FEGLI beneficiary prior to divorce; Maretta remained the named beneficiary after divorce and remarriage.
- Warren died in 2008; Maretta collected the FEGLI proceeds as the named beneficiary.
- Hillman sued in Virginia court seeking recovery under Section D; the Virginia Supreme Court held Section D pre-empted by FEGLIA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Section D is pre-empted by FEGLIA. | Hillman argues federal law requires FEGLIA priority to the named beneficiary and Section D conflicts. | Maretta contends Virginia law should provide recovery under Section D despite FEGLIA. | Section D is pre-empted by FEGLIA. |
Key Cases Cited
- Wissner v. Wissner, 338 U.S. 655 (1950) (pre-emption of state marital-property rules conflicting with federally designated beneficiary)
- Ridgway v. Ridgway, 454 U.S. 46 (1981) (constructive trusts on insurance proceeds; beneficiary designation rules)
- Crosby v. National Foreign Trade Council, 530 U.S. 363 (2000) (conflict pre-emption framework for state vs federal law)
- Hines v. Davidowitz, 312 U.S. 52 (1941) (conflict pre-emption based on congressional purposes and objectives)
