## Facts

- Isaac Boggs worked for South Central Bell (1949–1985) and accrued retirement benefits under ERISA-governed plans.
- During retirement, Isaac received a monthly annuity and also received plan-related assets, including a lump-sum distribution rolled into an IRA and shares from an employee stock plan.
- Isaac was married to Dorothy Boggs while the pension benefits accrued; Dorothy died in 1979.
- Dorothy’s will purported to transfer her Louisiana community-property interest in Isaac’s undistributed pension benefits, giving Isaac a lifetime usufruct over part of the property and giving their sons the remaining interests subject to that usufruct.
- Isaac later married Sandra Jean Dale Boggs, who remained his spouse until his death in 1989.
- After Isaac’s death, Sandra claimed entitlement to the ERISA benefits as surviving spouse, including survivor annuity rights; Isaac’s sons claimed rights based on Dorothy’s testamentary transfer of her community-property share.

## Issues

1. Whether ERISA preempts a state community-property rule that permits a nonparticipant spouse to transfer by will an interest in the participant’s undistributed pension benefits.
2. Whether such state-law claims may reduce or reallocate ERISA-protected survivor annuity benefits owed to a surviving spouse.
3. Whether ERISA preempts state-law claims to assets derived from plan distributions (including an IRA funded by a plan distribution and stock received from an employee stock plan).

## Decision

- The Supreme Court reversed, holding (5–4) that ERISA preempts state law allowing a nonparticipant spouse to transfer by testamentary instrument an interest in undistributed pension plan benefits.
- Louisiana community-property law was preempted to the extent it would give the sons a right to any portion of the surviving spouse’s qualified joint and survivor annuity.
- The sons’ state-law claims to a portion of the monthly annuity payments and to plan-derived assets (including the IRA funded with plan assets and employee stock plan shares) were also preempted.
- The Court applied conflict preemption principles, concluding the state rule would frustrate ERISA’s objectives of uniform plan administration and statutory protection for surviving spouses.

## Legal Principles

- ERISA preempts state community-property and succession rules that allow a deceased nonparticipant spouse to transfer by will an interest in a participant’s undistributed plan benefits when the transfer conflicts with ERISA’s benefit structure.
- ERISA’s survivor annuity provisions protect the surviving spouse’s stream of income; state-law transfers that would diminish that entitlement are displaced.
- Even a plan participant cannot unilaterally defeat the surviving spouse’s statutory survivor annuity without the spouse’s consent; ERISA does not permit a predeceasing nonparticipant spouse to accomplish indirectly what the participant cannot do directly.
- State-law claims that would reorder the federal scheme governing who may receive plan benefits, and on what terms, are preempted, including claims directed at assets derived from plan distributions when premised on reallocation of plan benefits.

## Conclusion

ERISA displaces state community-property rules that would permit a deceased nonparticipant spouse to divert undistributed pension benefits by will in a manner that reduces or reallocates ERISA-protected benefits, particularly the surviving spouse’s statutory survivor annuity, and it likewise preempts state-law claims seeking a share of plan-derived retirement assets based on that theory.


Boggs v. Boggs, 520 U.S. 833 (1997)