Duggins v. Fluor Daniel, Inc., 217 F.3d 317 (5^th Cir. 2000)-This court found that the district court erred in applying Louisiana law to the question of whether decedent C. Fred Newsom had properly designated his attorney as personal beneficiary of his ERISA plan (rather than simply as executor of his estate). This court stated that the law the district court used to interpret the designation of a beneficiary under the plan clearly "relates to" the plan, and thus, ERISA preempts Louisiana law in this arena.

However, this court then pointed out that a court need not even reach the issue of preemption where it can "resolve the validity of the [designation] without going beyond the terms of the plan itself." Nickel v. Estes, 122 F.3d 294, 298 (5th Cir. 1997). Here, the plain language designating the attorney as personal beneficiary of the plan controlled and no preemption analysis was necessary.