Federal court enforces beneficiary designation over divorce decree

ERISA generally overrides or "preempts" state laws, decrees, rulings, etc. An exception includes certain divorce decrees dividing spousal property that are "qualified domestic relations orders," commonly known as QDROs. 

In QuikTrip Corp. v. Javaher, (No. 14–CV–674–JHP–PJC) Judge Payne of the U.S. District Court for the Northern District of Oklahoma, considered a conflict between a divorce decree and a later beneficiary designation.  A 2011 divorce decree provided that a QuickTrip employee was to "maintain current beneficiaries," including his ex-wife, of life insurance policies. His ex-wife was the primary beneficiary of the ERISA policy at the time of the divorce However, in 2014 the employee changed the primary beneficiary of that policy to his fiancee.  He died a week later.

The Court held that the divorce decree did not qualify as a QDRO and did not prevent the employee from changing the primary beneficiary of that ERISA policy. The Court found that the divorce decree did not specifically reference the life insurance policy at issue or the prior designation in favor of the ex-wife.