03 June 2013

Law in Plain English: Hillman v. Maretta

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

Hillman v. Maretta

Warren Hillman, a federal government employee, died. Judy Maretta, Hillman's ex-wife, was the designated beneficiary of his life insurance policy. Jacqueline Hillman, Warren's widow, sued to obtain the proceeds of the policy. The Federal Employees Group Life Insurance Act of 1954 (FEGLIA) provides that the proceeds of federal life insurance plans shall be paid according to order of precedence, starting with the beneficiary or beneficiaries designated by the employee, and if there is no designated beneficiary, then the widow or widower of the employee received the proceeds, followed by the employee’s children and descendants, parents, the administrator of the employee’s estate, and anyone else entitled to receive the funds under state law. On the other hand, Virginia law provides that after divorce, the divorced spouses cease to be the designated beneficiaries of each other’s life insurance policies, and that the deceased person’s widow or widower instead becomes entitled to any benefits. Virginia's law also includes a second provision that created a cause of action for the widow to recover from the divorced spouse if the original provision was preempted (both parties agree that it was). Hillman prevailed at the Circuit Court of Fairfax County, but the Supreme Court of Virginia reversed. The question before the Court was whether FEGLIA preempts Virginia's domestic relations equitable remedy (the second provision) which creates a cause of action against the recipient of Hillman's life insurance proceeds after they have been distributed. In a unanimous decision (other than Justice Scalia not joining a footnote related to legislative history), the Supreme Court ruled that the Virginia statute is preempted by the Federal Employees Group Life Insurance Act. As a result, the practical impact of this decision is that Warren's widow cannot recover the proceeds of the policy under Virginia's law because it conflicts with federal law and is therefore invalid.
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