Hamilton

The alphabet soup world of pension benefits has spawned a dizzying array of acronyms, like ERISA, QDRO, and QPSA, and a complex web of interrelated statutory provisions. In a case of first impression, our challenge is to cut through the dense language to figure out what Congress meant in terms of surviving spouse benefits under the Employee Retirement Income Security Act of 1974 (“ERISA”), 88 Stat. 832 , as amended, 29 U.S.C. § 1001 et seq.

In the case before us, two ERISA-governed pension funds, the Plumbers & Pipe-fitters National Pension Fund (National Pension Fund) and the Washington State Plumbing & Pipefitting Industry Pension Plan for Local Union #32 (State Plan) (collectively the “Plans”), and Mary Hamilton, the surviving spouse of plan participant Michael Hamilton, appeal the district court’s summary judgment and award of attorneys’ fees to Michael’s children from a previous marriage, David and Sarah Hamilton (the “Children”). After Michael’s pre-retirement death, Mary and the Children claimed competing rights to survivor benefits. The district court found that the marital dissolution order, which required Michael to name the Children as beneficiaries under the Plans,…