In essence, this decision is a reaffirmation of the right and ability of the federal government to, at least in some instances, pre-empt state laws.

The case was considered under Washington state law wherein the designation of a spouse as beneficiary to "nonprobate asset," a life insurance policy or employee benefit plan, is revoked immediately upon the divorce of the designator and the beneficiary.

However, under ERISA, this was not the case, and Donna Rae Egelhoff would be the beneficiary of her late ex-husband's benefits.

The trial court decided that ERISA pre-empted Washington state law, and granted Donna Rae Egelhoff the benefits she sought.

The Supreme Court of Washington affirmed this decision, citing that, because the Statute did not "refer to" or have a "connection with" an ERISA plan, the state law would be most appropriate.