ERISA Preemption Does Not Apply to Bar Application of State Community Property Law to Force Redistribution of Life Insurance Proceeds despite Beneficiary Designation on Face of Policy
第九巡回上诉法院判决，尽管ERISA通常优先于州法，但本案中加州夫妻共同财产法应适用，允许现任配偶获得已故员工的人寿保险金，因为严格遵循受益人指定会过于不公且不尊重联邦与州的权力划分。
Emard v. Hughes Aircraft Company, __ F.3d __, 1998 U.S. App. LEXIS 20294 (United States Court of Appeals for the Ninth Circuit, August 20, 1998)(applying California law and federal law of ERISA preemption). Ginger Emard was an employee at Hughes Aircraft Company at the time of her death. When she began work at Hughes in 1981, she became eligible for the company's life insurance policy and designated her then-husband Alex Stencel as the beneficiary. She and Stencel divorced in 1985 and she remarried to Gary Emard in 1986 but did not change the beneficiary designation. In 1988, she purchased an optional term life insurance policy but failed to fill out a new designation of beneficiary form. Ms. Emard died intestate in 1995. The 1981 form designating Stencel as life insurance beneficiary remained the only document directing the distribution of the insurance proceeds. Mr. Emard filed suit to obtain policy proceeds but lost in the trial court. Under California's community property law, a current spouse is entitled to a decedent spouse's life insurance benefits as a matter of law. But under the Employee Retirement Income Security Act (ERISA), the documentary designation of a beneficiary is controlling unless it can be set aside under the federal common law of contract applicable in ERISA disputes. On appeal, the United States Court of Appeals for the Ninth Circuit reversed the trial court and awarded the policy benefits to Mr. Emard as current husband. The Ninth Circuit reasoned that ERISA was not controlling even though ERISA has a broad preemption clause that makes it applicable when in conflict with most state laws regulating benefits. However, in this case, the Court found no preemption because rigid application of the designation-of-beneficiary rule over important state policies that did not interfere with the federal statutory scheme was deemed by the Court to be too inequitable and insufficiently sensitive to the federal-state division of authority. The Court utilized a two-step analysis drawn from Supreme Court precedent asking (1) whether California law conflicts with any specific provision of ERISA and (2) whether application of California law would frustrate Congress' purposes in enacting ERISA. If no conflict of this sort is found and there is no indication that Congress sought to occupy this field completely through federal law, preemption is not required. State law traditionally has been the realm in which both the distribution of estates and the resolution of family law matters has taken place. …