This case presented the question whether ERISA preempts state laws allowing non-participating spouses to acquire and transfer interests in undistributed pension plan benefits. Respondents are the sons of Isaac and Dorothy Boggs. Under Louisiana law, Dorothy acquired, and then bequeathed to her sons, a community-property interest in Isaac's undistributed pension benefits. Isaac bequeathed all of his property to his second wife, petitioner Sandra Boggs. Sandra argued that ERISA preempted Dorothy's purported acquisition and testamentary transfer of Isaac's undistributed pension benefits, and that she (Sandra) was therefore entitled to all of those benefits. The Supreme Court agreed.
Seven Justices concluded that ERISA preempted Louisiana law to the extent that it purported to give respondents a portion of the "qualified joint and survivor annuity" defined in Section 1055 of ERISA. Section 1055(a) states that a pension plan "shall provide" for such an annuity payable to a non-participating surviving spouse; Sec.1055(d)(1) specifies the minimum amount of the survivor's annuity; and Sec. 1055©(2) prohibits the participant from waiving the survivor's annuity (except in limited circumstances not present in this case). The Court held that Louisiana law conflicted with, and was thus preempted by, Sec. 1055.
Five Justices also concluded that ERISA preempted Louisiana law even with respect to pension funds not covered by the survivor's annuity. The Court relied both on the text of Section 1056(d)(1) of ERISA, which states that a pension plan "shall provide that benefits provided under the plan may not be assigned or alienated," and on the overall structure of ERISA, which confers beneficiary status on non-participating spouses only in "narrow circumstances" not present in this case.