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CourtListener opinion 201660

Citation: domestic relations order · Date unknown · US

Extracted case name
pending
Extracted reporter citation
domestic relations order
Docket / number
pending
QDRO relevance 5/5Retirement relevance 2/5Family-law relevance 5/5gold label pending
Research-use warning: This page contains machine-draft public annotations generated from public opinion text. The headnote is not Willie-approved gold-label work product and is not legal advice. Verify the full opinion and current law before relying on it.

Machine-draft headnote

Machine-draft public headnote: CourtListener opinion 201660 is included in the LexyCorpus QDRO sample set as a public CourtListener opinion with relevance to QDRO procedure / domestic relations order issues. The current annotation is conservative: it identifies source provenance, relevance signals, and evidence quotes for attorney/agent retrieval. It is not a Willie-approved legal headnote yet.

Retrieval annotation

Draft retrieval summary: this opinion has QDRO relevance score 5/5, retirement-division score 2/5, and family-law score 5/5. Use the quoted text and full opinion below before relying on the case.

Category: QDRO procedure / domestic relations order issues

Evidence quotes

domestic relations order

olding that FEGLIA preempted -4- the state law claim, the court relied on FEGLIA's (1) language and scheme, (2) the overwhelming weight of federal court authority holding FEGLIA's provisions preempt state law, and (3) a 1998 amendment to FEGLIA allowing domestic relations orders to alter FEGLIA's benefit distribution scheme under specified circumstances. Id. at 346-48. We have carefully reviewed the record, the applicable law, and the parties' briefs, and conclude the district court reached the correct result. We have repeatedly opined that "when a lower court accurately takes the measure of a case and articulates a cogent

Source and provenance

Source type
courtlistener_qdro_opinion_full_text
Permissions posture
public
Generated status
machine draft public v0
Review status
gold label pending
Jurisdiction metadata
US
Deterministic extraction
reporter: domestic relations order
Generated at
May 14, 2026

Related public corpus pages

Deterministic links based on shared title/citation terms and QDRO / retirement / family-law retrieval scores.

Clean opinion text

United States Court of Appeals
 For the First Circuit

No. 04-2469

 METROPOLITAN LIFE INSURANCE COMPANY,

 Plaintiff,

 v.

 BEVERLY A. ZALDIVAR,

 Defendant, Appellee,

 &

 SANDRA L. ZALDIVAR, DANIEL C.E. ZALDIVAR,
 and THOMAS A. ZALDIVAR,

 Defendants, Appellants.

 APPEAL FROM THE UNITED STATES DISTRICT COURT

 FOR THE DISTRICT OF MASSACHUSETTS

 [Hon. Michael A. Ponsor, U.S. District Judge]

 Before
 Lynch, Circuit Judge,
 Baldock,* Senior Circuit Judge,
 and Lipez, Circuit Judge.

 Sean J. Cleary for appellee.

 Mark J. Albano, with whom Dalsey, Ferrara & Albano was on the
brief, for appellants.

 June 27, 2005

 *
 Of the Tenth Circuit Court of Appeals, sitting by
designation.
 BALDOCK, Senior Circuit Judge. The sole issue before us

on appeal is whether the Federal Employees Group Life Insurance Act

(FEGLIA), 5 U.S.C. §§ 8701-8716, preempts a state law claim for the

imposition of a constructive trust upon the proceeds of a federal

group life insurance policy. We hold that it does.

 The facts are not in dispute. Decedent Albert Zaldivar

was an employee of the United States Postal Service. A state

divorce decree from his first marriage (originally entered in New

York and subsequently ratified in New Hampshire) directed decedent

to name his three children, Appellants Sandra L. Zaldivar, Daniel

C.E. Zaldivar, and Thomas A. Zaldivar, as beneficiaries of his

federal group life insurance policy. Notwithstanding the decree,

decedent named his second wife, Appellee Beverly Zaldivar, as sole

beneficiary of the policy once his children reached adulthood.

 Upon decedent's death in June 2001, the policy issuer,

Metropolitan Life Insurance Company (MetLife), initiated this

interpleader action in federal district court. See Fed. R. Civ. P.

22. The district court permitted disbursement of the policy

proceeds to Beverly. Thereafter, the children moved the court,

pursuant to state law, to impose a constructive trust on the

proceeds. The court denied the motion and entered judgment in

favor of Beverly, holding FEGLIA preempted the children's state law

claim.

 The district court issued a thorough, well-reasoned

opinion. Metropolitan Life Ins. Co. v. Zaldivar, 337 F. Supp. 2d

343 (D. Mass. 2004). To support its holding that FEGLIA preempted

 -4-
 the state law claim, the court relied on FEGLIA's (1) language and

scheme, (2) the overwhelming weight of federal court authority

holding FEGLIA's provisions preempt state law, and (3) a 1998

amendment to FEGLIA allowing domestic relations orders to alter

FEGLIA's benefit distribution scheme under specified circumstances.

Id. at 346-48.

 We have carefully reviewed the record, the applicable

law, and the parties' briefs, and conclude the district court

reached the correct result. We have repeatedly opined that "when

a lower court accurately takes the measure of a case and

articulates a cogent rationale, it serves no useful purpose for a

reviewing court to write at length." Seaco Ins. Co. v. Davis-

Irish, 300 F.3d 84, 86 (1st Cir. 2002) (citing cases). Thus, we

affirm the district court's judgment for substantially the reasons

set forth in its opinion. We add only these brief comments.

 The Supreme Court's decision in Ridgway v. Ridgway, 454

U.S. 46 (1981), dictates the outcome of this case. In Ridgway, the

issue was whether a serviceman's beneficiary designation under a

policy governed by the Servicemen's Group Life Insurance Act

(SGLIA), 38 U.S.C. §§ 1965-1979, prevailed over a constructive

trust (based on a divorce decree) which a state court imposed upon

the policy proceeds. Like FEGLIA, SGLIA establishes a specified

"order of precedence" for policy beneficiaries. Subsection (a) of

both 5 U.S.C. § 8705 and 38 U.S.C. § 1970 provides that policy

proceeds shall first be paid to the insured's properly designated

beneficiary. Because the applicable language of FEGLIA and SGLIA

 -5-
 are very similar, a case construing the latter, such as Ridgway, is

highly persuasive, if not binding, in construing the former. See

Metropolitan Life Ins. Co. v. Christ, 979 F.2d 575, 580-82 (7th

Cir. 1992); see also Prudential Ins. Co. v. Hinkel, 121 F.3d 364,

367 (8th Cir. 1997); Brewer v. Zawrotny, 978 F.2d 1204, 1206 n.2

(10th Cir. 1992).

 The Court in Ridgway concluded that Congress, in enacting

SGLIA, "spoke[] with force and clarity in directing that the

proceeds belong to the named beneficiary and no other." Ridgway,

454 U.S. at 56 (internal quotations omitted). Thus, we are bound

to conclude the state divorce decree directing the decedent to

designate his children as beneficiaries under his life insurance

policy conflicted with the decedent's right under FEGLIA to name

the beneficiary, and must give way. See Christ, 979 F.2d at 582.

 Finally, we note the children could have avoided today's

result if they had complied with the 1998 amendment to FEGLIA prior

to decedent's death in 2001. See Pub. L. No. 105-205, § 1, 112

Stat. 683 (July 22, 1998). Cognizant of the possible inequities in

cases such as this, Congress created an exception to the insured's

unfettered right to name the beneficiary of his or her choosing

under § 8705(a). Subsection (a) is now subject to § 8705(e).

Subsection (e) provides that domestic decrees may alter the order

of precedence set forth in subsection (a) if "received, before the

date of the covered employee's death," by the appropriate agency or

office. As the district court explained: "To alter the designation

of a beneficiary in this case by imposing a constructive trust

 -6-
 would directly contradict the language of § 8705(e) that

specifically mandates the conditions that must be met for a court

divorce decree to be given effect." Zaldivar, 337 F. Supp. 2d at

348.

 AFFIRMED.

 Each party shall bear their own costs on appeal.

 -7-