184 F. Supp. 2d 642 - Seaman v. Johnson’s Empirical Analysis
2002
Citation profile
1 state decisions
Relationships
Applies 29 U.S.C. § 1001 (§ 2 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1002 (§ 3 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1056 (§ 206 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1104 (§ 404 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1144 (§ 514 of the Employee Retirement Income Security Act of 1974)
Relies on Anderson v. Liberty Lobby, Inc. · Celotex Corporation v. Catrett H · Pilot Life Insurance v. Dedeaux · Donna Rae Egelhoff v. Samantha Egelhoff Kate Breiner David Egelhoff · McMillan v. Parrott
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]n the instant case, there were conditions in the [qualified domestic relations order] regarding the children’s designation as beneficiaries. Decedent was to keep them as beneficiaries for as long as he had an obligation to provide child support. The provision specifically provided for the “irrevocable]” designation of the children as beneficiaries to Decedent’s life insurance policy; however, that clause is modified by the very next provision, providing that Decedent only had to continue the children as beneficiaries “until such time as his obligation to support minor children as hereinbefore provided shall have been terminat ed.” In other words, the divorce decree operated to change the beneficiary; at his death, Decedent was no longer obligated to support the children. Because the [qualified domestic relations order] erased the 1969 beneficiary designation of Plaintiff, replaced her with [the children], but then expired by its terms, there was, in effect, no beneficiary designated on Decedent’s policy at the time of his death. This Court is required, under Egelhojf and well-settled law, to look to the “plan documents” to determine to whom benefits are to be paid. The plan in this case provides that if, at the time of Decedent’s death, there is no designated beneficiary, then the benefits are payable to the Estate. Based on the analysis above, since effectively there was no beneficiary designation at the time of Decedent’s death, the insurance benefits should pass to the ”
1 later decision quote this exact passage · from the majority“IT IS FURTHER ORDERED AND ADJUDGED that the Plaintiff, Carl Johnson, shall pay to the Defendant, Antoinette Johnson, weekly in advance, through the office of the Friend of the Court for Genesee County, Michigan, for the support and maintenance of said minor children, the following amounts: During the time that there are two (2) minor children eligible for support the sum of $62.00 shall be paid; During the time that there is one (1) minor child eligible for support the sum of $37.00 shall be paid. ... [A]s further support for said minor children, the Plaintiff shall forthwith irrevocably designate the said minor children ... as beneficiaries of any life insurance policies he may by virtue of his employment, have with Chevrolet V-8. and he shall contiue [sic] said minor children as beneficiaries of said insurance policies or any other group policies he may have in connection with his employment until such time as his obligation to support minor children ... shall have been terminated.... ... [T]he Defendant, Antoinette Johnson shall hereafter have no further interest as beneficiary or otherwise in or to the life insurance policies endowmwnt [sic], or annuity contracts standing in the name of or insuring the life of the Plaintiff, Carl Johnson.”
1 later decision quote this exact passage · from the majority“The divorce decree at issue in the instant case substantially complies with the requirements of § 1056(d)(3). It names the children as alternate payees, and lists the addresses of the children and the participant (Decedent). It specifies the plan with enough information so that the plan can be readily identified (“life insurance policies ... by virtue of his employment ... with Chevrolet V-8”). Although it does not specify the percentage of the benefits to be paid to each child, the plan itself provides for equal distribution if there is more than one beneficiary listed. And although it did not specify “the number of payments or periods for which such order applies,” the court in Marsh found that factor irrelevant in a life insurance plan context, since the benefits would be paid in a lump sum at decedent’s death. Like the Marsh order, the instant order does not lack any essential information. Therefore, under Marsh , because it substantially complies with the requirements, the 1976 divorce decree should be treated as a QDRO.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.