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Hillman v. Maretta
133 S. Ct. 1943
| SCOTUS | 2013
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Background

  • 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)
Read the full case

Case Details

Case Name: Hillman v. Maretta
Court Name: Supreme Court of the United States
Date Published: Jun 3, 2013
Citation: 133 S. Ct. 1943
Docket Number: 11–1221.
Court Abbreviation: SCOTUS