Marriage of Angell v. Angell

Summary

The Minnesota Supreme Court held that federal anti-attachment provisions governing Servicemembers’ Group Life Insurance proceeds and military death gratuity benefits preempted a state court’s award of a portion of those benefits to a non-beneficiary spouse in a dissolution proceeding. The court characterized the award under Minnesota’s unfair-hardship property-division statute as a division of property rather than a support obligation. The court affirmed the court of appeals’ reversal of the award.

Holdings

1. Federal law preempts a state dissolution court's award of a portion of SGLI proceeds and federal death gratuity benefits to a non-beneficiary spouse because 38 U.S.C. §§ 1970(g) and 5301(a)(1) prohibit attachment, levy, seizure, or other diversion of the benefits from the designated beneficiary.
2. An award under Minn. Stat. § 518.58, subdivision 2, apportioning nonmarital property to prevent unfair hardship is a property division, not a spousal-support obligation, and is therefore subject to federal preemption when it diverts protected federal death benefits from the designated beneficiary.

Questions Presented

1. Whether federal anti-attachment provisions governing SGLI and federal death gratuity benefits preempt a Minnesota dissolution court's award of a portion of those benefits to a non-beneficiary spouse under Minn. Stat. § 518.58, subdivision 2.
2. Whether the unfair-hardship award constituted a support obligation exempt from federal preemption under the reasoning of Rose v. Rose.

Disposition

affirmed