Egelhoff v. Egelhoff, a Minor, by and Through Her Natural Parent, Breiner

Summary

The Court, in an opinion by Justice Thomas joined by Chief Justice Rehnquist and Justices O'Connor, Scalia, Kennedy, Souter, and Ginsburg, held that ERISA expressly preempts Washington's automatic revocation of a former spouse's beneficiary designation insofar as the statute applies to ERISA plans. The statute controls beneficiary selection contrary to plan documents and interferes with nationally uniform plan administration; neither its opt-out provision nor its operation in traditional areas of state regulation saves it. The Court reversed the Washington Supreme Court and remanded, leaving the treatment of slayer statutes undecided. Justice Scalia, joined by Justice Ginsburg, concurred, agreeing that the direct conflict triggered preemption but advocating interpretation of ERISA's preemption clause through ordinary conflict and field preemption principles. Justice Breyer, joined by Justice Stevens, dissented, viewing the statute as a permissible default interpretive rule that neither directly conflicts with ERISA nor significantly burdens plan administration.