Manning v. Hayes, 212 F.3d 866 (5th Cir. 2000)

Manning v. Hayes, 212 F.3d 866 (5^th Cir. 2000)-This appeal concerns a dispute between the estate of a deceased ERISA plan participant and the decedent's ex-wife over life insurance benefits. This court affirmed the district court's summary judgment in favor of Allison Hayes, the ex-wife and the named beneficiary of his life insurance policy.

Hayes and her late husband Houghton West, had executed a prenuptial agreement which included a non-exhaustive list of each of the parties assets (for the purpose of keeping separate property separate), but made no mention of employee benefits or insurance proceeds generally, or the Unum policy in particular. During their marriage West designated Hayes as the beneficiary on the Unum policy. However, their divorce decree did not reiterate the designation of Hayes as beneficiary. Thus, West's estate disputed Hayes' entitlement to those benefits on the basis of the Texas Family Code § 9.301.

Since ERISA would clearly preempt the estate's claim to the extent that it relied on the Texas beneficiary redesignation statute, the estate argued that the Fifth Circuit had adopted the statute into the federal common law in Brandon v. Travelers Ins. Co., 18 F.3d 1321 (5^th Cir. 1994). This court agreed that Brandon was good law, and that it was appropriate to look to federal common law (instead of just the strict language of the plan), but found that the divorce decree in this case did not explicitly divest the ex-spouse of the interest in the benefit plan, as was the case in Brandon.