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Kennedy v. Plan Administrator for DuPont Savings and Investment Plan
United States Supreme Court
555 U.S. 285 (2009)
William Kennedy had a savings and investment plan with his employer, DuPont, which was an ERISA employee pension benefits plan (the plan). William designated his wife, Liv Kennedy, as the beneficiary of the plan. William and Liv later divorced. The divorce decree divested Liv of any interest in any pension plan of William’s. William did not execute any documents removing Liv as the beneficiary of the plan, or designating another beneficiary. Liv did not execute and submit a qualified disclaimer of the benefits. Following William’s death, Kari Kennedy, as executrix of William’s estate, asked DuPont to distribute the plan’s funds to William’s estate. DuPont instead paid the plan’s funds to Liv, as the beneficiary named in the plan’s beneficiary designation form. Kari (plaintiff) sued DuPont and the savings and investment plan administrator (defendants), arguing that the divorce decree constituted a federal common law waiver of benefits by Liv. The district court ordered DuPont to pay the benefits to the estate. The Fifth Circuit Court of Appeals reversed, finding that Liv’s waiver was an assignment or alienation of her interest in the plan’s benefits, which is prohibited under ERISA.
Rule of Law
Holding and Reasoning (Souter, J.)
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