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Burnley, D. v. Loews Hotel

Pa. Super. Ct.March 5, 2026No. 370 EDA 2023
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Case Details

Citation
2026 Pa. Super. 43
Judge(s)
Lane; King; Beck; Bowes; Lazarus; Sullivan
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
summary judgment
State
Oregon
Circuit
9th Circuit

Related Laws

No specific laws identified for this ruling.

Outcome

The court granted the cross-motion for summary judgment filed by Debra A. McAlister and determined that the Stipulated General Judgment of Dissolution of Marriage qualifies as a Qualified Domestic Relations Order (QDRO) under ERISA, elevating child support obligations over the named beneficiary's claim to life insurance proceeds.

What This Ruling Means

**Court Rules on Life Insurance Benefits in Divorce Case** This case involved a dispute over who should receive life insurance benefits after a worker's death. Debra Burnley had been named as the beneficiary on her ex-husband's workplace life insurance policy through his employer, Ryder Transportation Co. However, when he died, his divorce agreement required that any life insurance money go toward child support payments instead of to the named beneficiary. The court ruled in favor of the child support obligations. The judge determined that the divorce agreement qualified as a special court order under federal employment law (called a QDRO), which means child support requirements can override who was originally named to receive life insurance benefits from workplace policies. This decision is important for workers because it shows that divorce agreements involving child support can change who receives your workplace benefits, even if you never updated your beneficiary forms. Workers going through divorce should carefully review all their workplace benefits - including life insurance, retirement accounts, and pensions - and make sure their beneficiary designations match what their divorce agreement requires. If there's a conflict, the court-ordered child support obligations may take priority over your named beneficiaries.

This summary was generated to explain the ruling in plain English and is not legal advice.

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