In re Estate of Easterday
209 A.3d 331
| Pa. | 2019Background
- Michael J. Easterday (Decedent) and Colleen A. Easterday married in 2004; Decedent named Colleen beneficiary of a $250,000 life insurance policy and his pension. They separated in 2013 and executed a Property Settlement Agreement (PSA) in December 2013; the PSA waived each spouse’s interest in the other’s pensions/retirement.
- Colleen filed for no-fault divorce under 23 Pa.C.S. § 3301(c) in August 2013; affidavits of consent are required for a mutual-consent divorce and Rule 1920.42(b)(2) requires each affidavit be filed within 30 days of execution to be valid for entry of decree.
- Decedent signed an affidavit on November 30, 2013; Colleen delayed filing and the prothonotary rejected Decedent’s affidavit as untimely when submitted in January 2014. Decedent never executed a second affidavit and died September 21, 2014; Colleen withdrew the divorce three days later.
- The Estate (Decedent’s son/executor) petitioned to recover life-insurance proceeds and pension funds: it argued § 6111.2 (PEF Code) voids a spouse beneficiary if the decedent died during divorce proceedings after grounds were established, and that the PSA waived Colleen’s pension rights.
- Orphans’ court awarded life-insurance proceeds to Colleen (because § 6111.2 did not apply) but awarded pension benefits to the Estate (enforcing the PSA waiver). Both parties appealed; the Superior Court affirmed both holdings; the Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument (Estate) | Defendant's Argument (Easterday) | Held |
|---|---|---|---|
| Whether Rule 1920.42(b)(2)’s 30‑day filing requirement is required to establish “grounds” under 23 Pa.C.S. § 3323(g)(2) (so that § 6111.2 voids spousal beneficiary if death occurs after grounds are established) | § 3323(g)(2)’s plain text says grounds are established when affidavits are filed; the statute contains no 30‑day timing requirement, so the Court may not read Rule 1920.42(b)(2) into the statute | The Rule’s 30‑day validity requirement has long been part of the procedural framework for mutual‑consent divorce; the legislature enacted § 3323(g)(2) against that background and therefore intended the same timing/validity constraint when applying § 3323(d.1) on death during proceedings | Court: Rule 1920.42(b)(2)’s 30‑day validity requirement operates with § 3323(g)(2); Decedent’s untimely affidavit did not establish grounds, so § 6111.2 did not void Colleen’s beneficiary designation (life‑insurance proceeds awarded to Colleen) |
| Whether ERISA preempts a state‑law contract claim by an estate to recover benefits already paid by a plan administrator to the named beneficiary under a PSA waiver | ERISA’s preemption is limited to laws that interfere with uniform plan administration; a post‑distribution contract claim between estate and beneficiary does not affect plan administration and thus is not preempted | Colleen contended ERISA should preempt enforcement of PSA waiver to protect uniformity and the beneficiary’s receipt of plan benefits | Court: ERISA does not preempt state‑law breach‑of‑contract claims to recover plan proceeds after the administrator has paid in accordance with plan documents; the Estate may enforce the PSA waiver against Colleen (pension proceeds awarded to Estate) |
Key Cases Cited
- Egelhoff v. Egelhoff ex rel. Breiner, 532 U.S. 141 (U.S. 2001) (state statute that alters beneficiary designation for ERISA plans conflicts with ERISA’s uniform plan administration and is preempted)
- Kennedy v. Plan Administrator for DuPont Sav. & Inv. Plan, 555 U.S. 285 (U.S. 2009) (ERISA requires plan administrators to follow plan documents; state rules that would change administrator payment obligations are preempted)
- Estate of Kensinger v. URL Pharma, 674 F.3d 131 (3d Cir. 2012) (post‑distribution state‑law claims by an estate against a beneficiary do not interfere with ERISA plan administration and are not preempted)
- In re Estate of Sauers, 32 A.3d 1241 (Pa. 2011) (Pennsylvania Supreme Court applying Egelhoff to hold that § 6111.2 is preempted as applied to ERISA plans in certain contexts)
- Tosi v. Kizis, 85 A.3d 585 (Pa. Super. 2014) (Superior Court decision discussing whether a surviving spouse may unilaterally discontinue a divorce after the other party dies; later disapproved by Pa.R.C.P. 1920.17(d) and this Court)