Boggs v. Boggs Case Brief Summary | Law Case Explained

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Boggs v. Boggs, 520 U.S. 833 (1997)
If your spouse contributes to a pension plan while you’re married, do you have any interest in those retirement benefits? Can you bequeath them in your will if you die first? We explore those questions in Boggs versus Boggs.
Isaac Boggs started working for South Central Bell when he was married to his first wife, Dorothy. Isaac and Dorothy remained married until Dorothy’s death. Dorothy’s will left Isaac a one third interest in her estate. It also left Isaac a lifetime usufruct, which is akin to a life estate, in the remainder of her estate. The couple’s sons received a naked interest in two thirds of Dorothy’s estate, subject to Isaac’s lifetime usufruct.
Isaac married Sandra shortly after Dorothy’s death. He retired from South Central several years later. At that time, Isaac received benefits from South Central’s retirement plan. He received a lump sum from the company’s savings plan, which he deposited into an individual retirement account, or IRA. He also received stock. Finally, he received monthly annuity payments. Isaac and Sandra remained married until Isaac died. Sandra then received monthly payments under the annuity as Isaac’s surviving spouse. Under Isaac’s will, Sandra received certain real property and a lifetime usufruct in the remainder of his estate.
Louisiana law governed Dorothy’s will. Louisiana is a community property state. In community property states, interest in pension benefits that accrue during a marriage belong to both spouses. Accordingly, under Louisiana law, Dorothy could leave her interest in Isaac’s undistributed pension benefits to their sons.
Dorothy’s sons filed an action in state court and sought a portion of Isaac’s pension benefits. Specifically, they sought a portion of Sandra’s survivor annuity payments, the annuity payments Isaac had received, the stock, and the IRA. Sandra then filed a declaratory judgment action in federal district court. She argued that the Employee Retirement Income Security Act, or ERISA, preempted Louisiana’s community property laws. Accordingly, Dorothy couldn’t leave her sons an interest in Isaac’s undistributed pension benefits via her will. The district court granted summary judgment to Dorothy’s sons. The Fifth Circuit affirmed. The United States Supreme Court granted cert.
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