Whether ERISA preempts a state-law claim to recover life insurance plan proceeds after distribution

QUESTION PRESENTED In Kennedy v. Plan Administrator for DuPont Savings & Investment Plan, 555 U.S. 285 (2009), this Court held that ERISA foreclosed a claim against a plan administrator seeking to force the administrator to pay out benefits to someone other than the beneficiary named in the plan documents. In the course of that decision, however, this Court expressly declined to decide whether a party “could have brought an action in state or federal court against [the named beneficiary] to obtain the benefits after they were distributed.” /d. at 300 n.10. Since Kennedy, federal and state courts have split over whether ERISA preempts a state-law claim brought to recover proceeds that have already been distributed. In this case, the Colorado court of appeals deepened the split by holding that a post-distribution claim is preempted under ERISA’s express-preemption clause. The question presented is: Whether, after an ERISA plan administrator has fully distributed life insurance plan proceeds, ERISA preempts a claimant’s state-law right to those proceeds.