Scott Andochick v. Ronald Byrd
709 F.3d 296
| 4th Cir. | 2013Background
- Andochick sued in federal court seeking a declaration that ERISA preempts a state-court waiver of ERISA-plan benefits.
- Erika Byrd died in 2011; benefits were payable to Andochick as named beneficiary, but she had pre-death waived those rights in a marital settlement agreement.
- Maryland state court ordered Andochick to renounce his interests, but the order did not decide ERISA’s effect on post- distribution disposition.
- ERISA governs the Venable 401(k) and life-insurance plans and their plan documents, including beneficiary designations.
- District court dismissed Andochick’s ERISA preemption claim; ordered plan administrators to pay funds to Andochick, who would then waive to Erika’s estate as directed by the state order.
- This appeal concerns whether ERISA preempts a post-distribution, state-law attempt to enforce a waiver against the plan beneficiaries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does ERISA preempt post-distribution suits enforcing a beneficiary waiver? | Andochick argues Kennedy supports preemption. | Byrds argue ERISA preempts waivers and post-distribution claims. | ERISA does not preempt post-distribution suits. |
| Do Boggs and Egelhoff compel preemption or defeat it here? | Andochick relies on Boggs and Egelhoff to invalidate post-distribution claims. | Byrds contend those cases support preemption or limit post-distribution actions. | Boggs and Egelhoff do not control; Kennedy guides the outcome. |
| Is res judicata or lack of standing dispositive? | Andochick argues no res judicata bar and proper standing. | Byrds argue district court erred on standing and res judicata. | Res judicata does not bar; standing and preemption arguments resolved on merits. |
Key Cases Cited
- Kennedy v. Plan Admin. for DuPont Savings & Investment Plan, 555 U.S. 285 (2009) (ERISA must pay named beneficiary; post-distribution effects unresolved.)
- Estate of Kensinger v. URL Pharma, Inc., 674 F.3d 131 (3d Cir. 2012) (Post-distribution suits do not defeat ERISA objectives.)
- Boggs v. Boggs, 520 U.S. 833 (1997) (ERISA preemption of state-law claims; distinguishes undistributed vs distributed benefits.)
- Egelhoff v. Egelhoff ex rel. Breiner, 532 U.S. 141 (2001) (Preemption when state law directs payment contrary to plan documents.)
- Appleton v. Alcorn, 728 S.E.2d 549 (Ga. 2012) (State-court treatment of ERISA waivers; aligns with Kennedy approach.)