Sveen v. Melin
U.S. Supreme Court · decided June 11, 2018 · Supreme Court Database (Spaeth)
- Decided
- June 11, 2018
- Term
- October Term 2017
- Vote
- 8–1
- Majority author
- Justice Kagan
- Issue area
- Economic Activity
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice KAGAN delivered the opinion of the Court. A Minnesota law provides that "the dissolution or annulment of a marriage revokes any revocable[ ] beneficiary designation[ ] made by an individual to the individual's former spouse." Minn. Stat. § 524.2-804, subd. 1 (2016). That statute establishes a default rule for use when Minnesotans divorce. If one spouse has made the other the beneficiary of a life insurance policy or similar asset, their divorce automatically revokes that designation-on the theory that the policyholder would want that result. But if he does not, the policyholder may rename the ex-spouse as beneficiary. We consider here whether applying Minnesota's automatic-revocation rule to a beneficiary designation made before the statute's enactment violates the Contracts Clause of the Constitution. We hold it does not. I All good trust-and-estate lawyers know that "[d]eath is not the end; there remains the litigation over the estate." 8 The Collected Works of Ambrose Bierce 365 (1911). That epigram, beyond presaging this case, helps explain the statute at its center. The legal system has long used default rules to resolve estate litigation in a way that conforms to decedents' presumed intent. At common law, for example, marriage automatically revoked a woman's prior will, while marriage and the birth of a child revoked a man's. See 4 J. Kent, Commentaries on…
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