Metro. Life Ins. v. Zaldivar, 413 F.3d 119 (1st Cir. 2005). · Go Syfert
Metro. Life Ins. v. Zaldivar, 413 F.3d 119 (1st Cir. 2005). Cases Citing This Book View Copy Cite
“because the applicable language of feglia and sglia are very similar, a case construing the latter . . . is highly persuasive, if not binding, in construing the former.”
26 citation events (26 in the last 25 years) across 12 distinct courts.
Strongest positive: Metropolitan Life Insurance Company v. Beard (mad, 2019-02-07)
Treatment trajectory · 2007 → 2026 · click a year to view as-of
2007 2016 2026
Top citers, strongest first. 18 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Metropolitan Life Insurance Company v. Beard
D. Mass. · 2019 · quote attribution · 1 verbatim quote · confidence high
because the applicable language of feglia and sglia are very similar, a case construing the latter . . . is highly persuasive, if not binding, in construing the former.
cited Cited as authority (rule) Gunter v. State of Oklahoma
10th Cir. · 2025 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir. 2005) (Baldock, J., sitting by designation) (internal quotation marks omitted).
cited Cited as authority (rule) P.W. v. Commissioner, SSA
10th Cir. · 2025 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir. 2005) (Baldock, J., sitting by designation) (internal quotation marks omitted).
discussed Cited as authority (rule) Estate of Michael Tarasevich v. Federal Retirement Thrift Investment Board
D.R.I. · 2022 · confidence medium
Zaldivar when FEGLIA preempted a state law claim relying on a divorce decree, the order of precedence under FEGLIA preempted the state law claim for a constructive trust. 413 F.3d 119, 120 (1st Cir, 2005) (citing Ridgeway, 454 U.S. at 70 ).
cited Cited as authority (rule) Salazar v. Whisker
10th Cir. · 2020 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir. 2005) (Baldock, J., sitting by designation) (quoting Seaco Ins.
cited Cited as authority (rule) MK International v. Crown Products & Services
10th Cir. · 2020 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir. 2005) (Baldock, J., sitting by designation) (quoting Seaco Ins.
discussed Cited as authority (rule) HERRICK v. MONTEJANO
D. Me. · 2019 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir. 2005), the First Circuit held that FEGLI rules for distribution preempt “a state law claim for the imposition of a constructive trust upon the proceeds of a federal group life insurance policy.” ( 5 U.S.C. § 8709 (d)(1) states: “The provisions of any contract under this chapter which relate to the nature or extent of coverage or benefits (including payments with respect to benefits) shall supersede and preempt any law of any State or political subdivision thereof, or any regulation issued thereunder, which relates to group life insurance to t…
discussed Cited as authority (rule) Rocket Real Estate, LLC v. Lourdes Maestres
11th Cir. · 2019 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir. 2005) (quoting Seaco Ins.
cited Cited as authority (rule) Chazz Alden Hughes v. R Allen Hughes
Tenn. Ct. App. · 2017 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 121 (1st Cir. 2005); Metro Life Ins.
cited Cited as authority (rule) Hardy v. Hardy
Ind. · 2012 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 121 (1st Cir.2005)).
examined Cited as authority (rule) Hardy v. Hardy (3×) also: Cited "see"
Ind. Ct. App. · 2011 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 121 (1st Cir.2005) (citation omitted).
discussed Cited as authority (rule) Hillman v. Maretta (2×)
Fairfax Cir. Ct. · 2010 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir. 2005) (holding that FEGLIA preempted a state divorce decree which ordered the insured to maintain his FEGLI policy for the benefit of his children from his first marriage); Metropolitan Life Ins.
cited Cited as authority (rule) United States v. Schmidt (Janice)
10th Cir. · 2009 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir.2005) (per Baldock, J.).
cited Cited as authority (rule) Keo v. Mukasey
1st Cir. · 2008 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir.2005) (quoting Seaco Ins.
cited Cited as authority (rule) Rabbat v. Mukasey
1st Cir. · 2008 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir.2005) (quoting Seaco Ins.
cited Cited as authority (rule) Zhou Lu v. Mukasey
1st Cir. · 2008 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir.2005) (quoting Seaco Ins.
cited Cited as authority (rule) United States v. Bates
1st Cir. · 2008 · confidence medium
Co. v. Zaldi-var, 413 F.3d 119, 120 (1st Cir.2005).
cited Cited as authority (rule) Punsoda-Diaz v. Ford Motor Company
1st Cir. · 2007 · confidence medium
Co. v. Zaldivar, 413 F.3d 119, 120 (1st Cir.2005) (quoting Seaco Ins.
Retrieving the full opinion text from the archive…
METROPOLITAN LIFE INSURANCE COMPANY, Plaintiff,
v.
Beverly A. ZALDIVAR, Defendant, Appellee, and Sandra L. Zaldivar, Daniel C.E. Zaldivar, and Thomas A. Zaldivar, Defendants, Appellants
04-2469.
Court of Appeals for the First Circuit.
Jun 27, 2005.
413 F.3d 119
Sean J. Cleary, for appellee., Mark J. Albano, with whom Dalsey, Fer-rara & Albano was on the brief, for appellants.
Lynch, Baldock, Lipez.
Cited by 20 opinions  |  Published
[*120] BALDOCK, Senior Circuit Judge.

The sole issue before us on appeal is whether the Federal Employees Group Life Insurance Act (FEGLIA), 5 U.S.C. §§ 8701-8716, preempts a state law claim for the imposition of a constructive trust upon the proceeds of a federal group life insurance policy. We hold that it does.

The facts are not in dispute. Decedent Albert Zaldivar was an employee of the United States Postal Service. A state divorce decree from his first marriage (originally entered in New York and subsequently ratified in New Hampshire) directed decedent to name his three children, Appellants Sandra L. Zaldivar, Daniel C.E. Zaldivar, and Thomas A. Zal-divar, as beneficiaries of his federal group life insurance policy. Notwithstanding the decree, decedent named his second wife, Appellee Beverly Zaldivar, as sole beneficiary of the policy once his children reached adulthood.

Upon decedent’s death in June 2001, the policy issuer, Metropolitan Life Insurance Company (MetLife), initiated this inter-pleader action in federal district court. See Fed.R.Civ.P. 22. The district court permitted disbursement of the policy proceeds to Beverly. Thereafter, the children moved the court, pursuant to state law, to impose a constructive trust on the proceeds. The court denied the motion and entered judgment in favor of Beverly, holding FEGLIA preempted the children’s state law claim.

The district court issued a thorough, well-reasoned opinion. Metropolitan Life Ins. Co. v. Zaldivar, 337 F.Supp.2d 343 (D.Mass.2004). To support its holding that FEGLIA preempted the state law claim, the court relied on FEGLIA’s (1) language and scheme, (2) the overwhelming weight of federal court authority holding FEGLIA’s provisions preempt state law, and (3) a 1998 amendment to FEG-LIA allowing domestic relations orders to alter FEGLIA’s benefit distribution scheme under specified circumstances. Id. at 346-48.

We have carefully reviewed the record, the applicable law, and the parties’ briefs, and conclude the district court reached the correct result. We have repeatedly opined that “when a lower court accurately takes the measure of a case and articulates a cogent rationale, it serves no useful purpose for a reviewing court to write at length.” Seaco Ins. Co. v. Davis-Irish, 300 F.3d 84, 86 (1st Cir.2002) (citing cases). Thus, we affirm the district court’s judgment for substantially the reasons set forth in its opinion. We add only these brief comments.

The Supreme Court’s decision in Ridgway v. Ridgway, 454 U.S. 46, 102 S.Ct. 49, 70 L.Ed.2d 39 (1981), dictates the outcome of this case. In Ridgway, the issue was whether a serviceman’s beneficiary designation under a policy governed by the Servicemen’s Group Life Insurance Act (SGLIA), 38 U.S.C. §§ 1965-1979, prevailed over a constructive trust (based on a divorce decree) which a state court imposed upon the policy proceeds. Like FEGLIA, SGLIA establishes a specified “order of precedence” for policy beneficiaries. Subsection (a) of both 5 U.S.C. § 8705 and 38 U.S.C. § 1970 provides that policy proceeds shall first be paid to the insured’s properly designated beneficiary. Because the applicable language of FEG-LIA and SGLIA are very similar, a case construing the latter, such as Ridgway, is highly persuasive, if not binding, in construing the former. See Metropolitan Life Ins. Co. v. Christ, 979 F.2d 575, 580-82 (7th Cir.1992); see also Prudential Ins. Co. v. Hinkel, 121 F.3d 364, 367 (8th Cir.1997); Brewer v. Zawrotny, 978 F.2d 1204, 1206 n. 2 (10th Cir.1992).

[*121] The Court in Ridgway concluded that Congress, in enacting SGLIA, “spoke[] with force and clarity in directing that the proceeds belong to the named beneficiary and no other.” Ridgway, 454 U.S. at 56, 102 S.Ct. 49 (internal quotations omitted). Thus, we are bound to conclude the state divorce decree directing the decedent to designate his children as beneficiaries under his life insurance policy conflicted with the decedent’s right under FEGLIA to name the beneficiary, and must give way. See Christ, 979 F.2d at 582.

Finally, we note the children could have avoided today’s result if they had complied with the 1998 amendment to FEGLIA pri- or to decedent’s death in 2001. See Pub.L. No. 105-205, § 1, 112 Stat. 683 (July 22, 1998). Cognizant of the possible inequities in cases such as this, Congress created an exception to the insured’s unfettered right to name the beneficiary of his or her choosing under § 8705(a). Subsection (a) is now subject to § 8705(e). Subsection (e) provides that domestic decrees may alter the order of precedence set forth in subsection (a) if “received, before the date of the covered employee’s death,” by the appropriate agency or office. As the district court explained: “To alter the designation of a beneficiary in this case by imposing a constructive trust would directly contradict the language of § 8705(e) that specifically mandates the conditions that must be met for a court divorce decree to be given effect.” Zaldivar, 337 F.Supp.2d at 348.

AFFIRMED.

Each party shall bear their own costs on appeal.