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Click here for the full text of this decision FACTS:Bradford Wayne Galaway and Kimberlye Finch married in September 2001 and divorced in June 2002. During the marriage, Galaway named Finch as the beneficiary of his employer group life insurance policy, which was governed by ERISA, with Guardian Life Insurance Co. In the divorce decree Galaway was awarded all “right, title, interest, and claim in and to” his life insurance policies, and Finch was divested of her interest. Nonetheless, Galaway did not remove Finch as the policy’s beneficiary. Galaway died in a plane crash in November 2002. He did not have a will. Eddie Lee Galaway, the administrator of Galaway’s estate, and Finch both claimed sole entitlement to the insurance proceeds. Guardian thus filed an interpleader action to the proper beneficiary identified. The magistrate judge applied federal common law to determine that Finch waived her right to the proceeds, and so ruled for the estate administrator. On appeal, Finch argues that magistrate judge erred in applying federal common law. She claims that the case of Egelhoff v. Egelhoff, 532 U.S. 141 (2001), undermines this court’s precedents calling for the application of federal common law to such situations. HOLDING:Affirmed. Egelhoff does not undermine this circuit’s past practice of applying federal common law to determine whether the named beneficiary of a plan governed by ERISA has waived her rights under the plan. The holding of Egelhoff is inapplicable to the present case, anyway, because Egelhoff does not address the application of federal common law to ERISA plans; it only addresses whether ERISA preempts a state statute that automatically revokes the designation of a spouse as the beneficiary of a life insurance policy upon divorce. Also, the goal of uniformity that the U.S. Supreme Court discusses in Egelhoff is not undermined when courts rely on the federal common law of waiver to determine if a beneficiary has waived her rights under an ERISA plan. Furthermore, the Egelhoff court strongly suggested that courts can at times rely on common law principles when determining the identity of the beneficiary of an ERISA plan. Finally, several post-Egelhoff decisions around the country have found that federal common law can still be applied. Only the 6th U.S. Circuit Court of Appeals has ruled that the text of ERISA precludes applying federal common law. OPINION:King, C.J.; King, C.J., Higginbotham and Davis, JJ.

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