Marriage of Angell v. Angell, 791 N.W.2d 530

This is a federal preemption case arising from a Minnesota dissolution of marriage between Gordon Angell, Jr. and Loretta Angell.
The district court treated the federal death gratuity and Servicemembers’ Group Life Insurance (SGLI) proceeds as marital/nonmarital property and divided them, including an award to Angell to prevent unfair hardship.
Respondent was the sole named beneficiary of the death benefits; nearly all checks were made out to or deposited for her.
The district court recharacterized respondent’s death benefits as nonmarital and then awarded $150,000 to Angell under Minnesota’s unfair-hardship provision, § 518.58, subd. 2.
The court of appeals held the federal anti-attachment provisions preempted any award of federal death benefits to Angell, and this Court affirmed preemption.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal anti-attachment statutes preempt a state-divorce award of federal death benefits to a non-beneficiary	Angell argues preemption blocks any share to him	Angell contends benefits belong to beneficiary only under federal law	Yes; federal law preempts the award to Angell

Ridgway v. Ridgway, 454 U.S. 46 (1981) (anti-attachment preempts state actions altering federal life-insurance proceeds)
Wissner v. Wissner, 338 U.S. 655 (1950) (anti-attachment preempts state diverts of benefits after payment)
Hisquierdo v. Hisquierdo, 439 U.S. 572 (1979) (anti-attachment provisions pre-empt state law in domestic relations context)
Rose v. Rose, 481 U.S. 619 (1987) (child support from veteran benefits can be exempt or not depending on purpose of benefits)
In re Barg, 752 N.W.2d 52 (Minn. 2008) (supremacy and preemption framework for federal/state conflict)