LexyCorpus case page
CourtListener opinion 2966935
Date unknown · US
- Extracted case name
- pending
- Extracted reporter citation
- 981 F.2d 160
- Docket / number
- pending
Machine-draft headnote
Machine-draft public headnote: CourtListener opinion 2966935 is included in the LexyCorpus QDRO sample set as a public CourtListener opinion with relevance to ERISA / defined contribution 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 5/5, and family-law score 5/5. Use the quoted text and full opinion below before relying on the case.
Category: ERISA / defined contribution issues
Evidence quotes
QDRO“summary judgment. 2 Relying on ERISA's preemption clause, the district court held that Betty's claim was preempted because it was based upon state law that related to an employee benefit plan. The district court noted further that Betty had not employed a qualified domestic relations order (QDRO), the method ERISA provided for a divorced spouse to enforce property rights in an ERISA plan. Accordingly, the district court granted Patricia's motion for summary judgment and denied Betty's summary judgment motion. The district court also denied Patricia's motion for attorney's fees and costs. On appeal, Betty contends that because an ERISA plan a”
ERISA“___________________________ OPINION WILLIAMS, Circuit Judge: Upon the death of one of its insured, Tom Pettit (Tom), Metropoli- tan Life Insurance Company (MetLife) sought to pay life insurance proceeds due under an Employee Retirement Income Security Act (ERISA) qualified plan. The designated beneficiary, Patricia Pettit (Patricia), who was Tom's widow, and Tom's former wife, Betty Pet- tit (Betty), both claimed a portion of the proceeds. Betty's claim was based on a property settlement agreement that she entered into with Tom in connection with their divorce. Faced with these competing claims, MetLife filed an in”
domestic relations order“udgment. 2 Relying on ERISA's preemption clause, the district court held that Betty's claim was preempted because it was based upon state law that related to an employee benefit plan. The district court noted further that Betty had not employed a qualified domestic relations order (QDRO), the method ERISA provided for a divorced spouse to enforce property rights in an ERISA plan. Accordingly, the district court granted Patricia's motion for summary judgment and denied Betty's summary judgment motion. The district court also denied Patricia's motion for attorney's fees and costs. On appeal, Betty contends that because an ERISA plan a”
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: 981 F.2d 160
- 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
PUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT METROPOLITAN LIFE INSURANCE COMPANY, Plaintiff, v. BETTY T. PETTIT, No. 97-2244 Defendant-Appellant, v. PATRICIA B. PETTIT, Defendant-Appellee. METROPOLITAN LIFE INSURANCE COMPANY, Plaintiff, v. PATRICIA B. PETTIT, No. 97-2407 Defendant-Appellant, v. BETTY T. PETTIT, Defendant-Appellee. Appeals from the United States District Court for the Eastern District of Virginia, at Alexandria. Claude M. Hilton, Chief District Judge. (CA-96-1311-A) Argued: September 23, 1998 Decided: December 31, 1998 Before MURNAGHAN and WILLIAMS, Circuit Judges, and BULLOCK, Chief United States District Judge from the Middle District of North Carolina, sitting by designation. _________________________________________________________________ Affirmed by published opinion. Judge Williams wrote the opinion, in which Chief Judge Bullock concurred. Judge Murnaghan wrote a sep- arate concurring opinion. _________________________________________________________________ COUNSEL ARGUED: Robert Eric Greenberg, FRIEDLANDER, MISLER, FRIEDLANDER, SLOAN & HERZ, Washington, D.C., for Appel- lant. Brian Stuart Chilton, HOGAN & HARTSON, L.L.P., Washing- ton, D.C., for Appellee. ON BRIEF: Glenn W. D. Golding, FRIEDLANDER, MISLER, FRIEDLANDER, SLOAN & HERZ, Washington, D.C., for Appellant. David G. Leitch, HOGAN & HARTSON, L.L.P., Washington, D.C., for Appellee. _________________________________________________________________ OPINION WILLIAMS, Circuit Judge: Upon the death of one of its insured, Tom Pettit (Tom), Metropoli- tan Life Insurance Company (MetLife) sought to pay life insurance proceeds due under an Employee Retirement Income Security Act (ERISA) qualified plan. The designated beneficiary, Patricia Pettit (Patricia), who was Tom's widow, and Tom's former wife, Betty Pet- tit (Betty), both claimed a portion of the proceeds. Betty's claim was based on a property settlement agreement that she entered into with Tom in connection with their divorce. Faced with these competing claims, MetLife filed an interpleader action to determine the proper disposition of the insurance proceeds. Betty filed a cross-claim against Patricia seeking to enforce a constructive trust against the dis- puted proceeds. Both parties to the cross-claim filed competing motions for summary judgment. 2 Relying on ERISA's preemption clause, the district court held that Betty's claim was preempted because it was based upon state law that related to an employee benefit plan. The district court noted further that Betty had not employed a qualified domestic relations order (QDRO), the method ERISA provided for a divorced spouse to enforce property rights in an ERISA plan. Accordingly, the district court granted Patricia's motion for summary judgment and denied Betty's summary judgment motion. The district court also denied Patricia's motion for attorney's fees and costs. On appeal, Betty contends that because an ERISA plan administra- tor should look outside of the plan provisions to allocate benefits properly and that this burden does not conflict with ERISA's policies, her constructive trust claim is not preempted. She also argues that although the district court did not reach the merits of her constructive trust claim, this Court may resolve those issues without remand. Patri- cia filed a cross-appeal challenging the district court's denial of her attorney's fees and costs. Because we agree that ERISA preempts the constructive trust claim and that no attorney's fees should be awarded in this case, we affirm the judgment of the district court. I. During divorce proceedings in 1989, Tom and Betty Pettit divided their marital property through a property settlement agreement, which was incorporated but not merged into their divorce decree, and a sepa- rate QDRO that was entered by the Circuit Court of Fairfax County, Virginia. The property settlement agreement provided for a division of personalty and realty, the payment of spousal support, and other general matters. That agreement also specifically required Tom to maintain $200,000 of life insurance benefits in favor of Betty1 and to transfer to Betty ownership of several life insurance policies issued by Connecticut Mutual, American Mutual, and Prudential. The trans- ferred policies are not at issue in this appeal. The QDRO transferred to Betty one-half of Tom's interest in his income savings plan, which _________________________________________________________________ 1 The life insurance provision also required Tom to provide at least annual proof of compliance therewith. Betty never received or requested such proof. 3 was maintained through his employer, but it made no mention of life insurance benefits. This appeal concerns the life insurance policy that Tom carried through his employer, the National Broadcasting Company (NBC), which was administered by MetLife. This life insurance policy was subject to the provisions of ERISA; it was not specifically mentioned in the property settlement agreement. Tom also owned and privately maintained other life insurance policies. The beneficiary designations on the policies were changed frequently, but at Tom's death, Betty was not named as the beneficiary of either the MetLife policy or any other policy that would fulfill the property settlement agreement's $200,000 insurance obligation.2 Unbeknownst to Betty, Tom had des- ignated his then wife, Patricia, as the beneficiary of the MetLife plan. Seeking to enforce the property settlement agreement, Betty pre- sented a claim to MetLife for a portion of the life insurance proceeds. Faced with competing payment obligations because Betty's claim clearly conflicted with the plan's beneficiary designation, MetLife filed an interpleader action in the United States District Court for the Eastern District of Virginia naming Betty Pettit and Patricia Pettit as defendant-claimants. Betty then filed a counterclaim against MetLife, which she later dismissed via consent order, and a cross-claim against Patricia to enforce a constructive trust against the MetLife proceeds. Upon cross motions for summary judgment, the district court granted Patricia's motion and denied Betty's. Subsequently, the district court denied Patricia's motion to obtain attorney's fees and costs from Betty. This appeal followed. II. The threshold question in this case is whether ERISA preempts the enforcement of a property settlement agreement against life insurance benefits paid through an ERISA-governed plan. Betty asks that we impose a constructive trust upon the life insurance proceeds if we find that ERISA does not preempt her claim. _________________________________________________________________ 2 The other policies variously named his children or Patricia as the ben- eficiaries. 4 We review the district court's grant of Patricia's motion for sum- mary judgment de novo. See M & M Med. Supplies & Serv. v. Pleas- ant Valley Hosp., Inc., 981 F.2d 160, 163 (4th Cir. 1992) (en banc). If there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law, then summary judgment is appropriate. See Fed. R. Civ. P. 56(c); M & M Medical, 981 F.2d at 162-63. As the district court found and the parties agree, there are no material facts in dispute. Our inquiry, therefore, necessarily extends only to the application of the law in this case. In any inquiry involving statutory construction, we begin with the language of the statute itself. Commonly known as ERISA's preemp- tion provision, 29 U.S.C.A. § 1144(a) states that ERISA \shall super-