In the Matter of the Estate of Michael D. Jones

CourtSupreme Court of New Jersey
DecidedJanuary 27, 2025
DocketA-28-23
StatusPublished

This text of In the Matter of the Estate of Michael D. Jones (In the Matter of the Estate of Michael D. Jones) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of the Estate of Michael D. Jones, (N.J. 2025).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

In the Matter of the Estate of Michael D. Jones, Deceased (A-28-23) (088877)

Argued September 10, 2024 -- Decided January 27, 2025

PIERRE-LOUIS, J., writing for a unanimous Court.

In this appeal, the Court considers whether an ex-spouse’s rights as the pay- on-death beneficiary on her deceased ex-husband’s U.S. savings bonds were superseded by the parties’ divorce.

Decedent Michael Jones purchased Series EE federal savings bonds while he was married to Jeanine Jones, and he designated Jeanine as the pay-on-death beneficiary. When the couple divorced, they entered into a divorce settlement agreement (DSA) that provided for the disposition of certain property but did not specifically list and dispose of the savings bonds. The DSA stated that any marital asset not listed “belongs to the party who has it currently in their possession.” The DSA further required Michael to pay Jeanine a total of $200,000 over a period of time in installments. After Michael’s death, Jeanine redeemed the savings bonds.

Jeanine filed a creditor’s claim against Michael’s Estate seeking to be reimbursed the $100,000 she claimed was still owed to her under the terms of the DSA. Michael’s Estate argued that Michael’s financial obligations to Jeanine were satisfied through her redemption of the savings bonds. The trial court agreed with the Estate that the savings bonds counted towards Michael’s $200,000 obligation under the DSA and dismissed Jeanine’s claim for reimbursement.

The Appellate Division reversed, holding that N.J.S.A. 3B:3-14, which governs the revocation of property transfers by divorce, conflicted with and was therefore preempted by federal law. 477 N.J. Super. 203, 224 (App. Div. 2023). The appellate court held that the value of the redeemed bonds should not be credited towards the Estate’s DSA obligations because Jeanine was the sole owner of the bonds at the time of Michael’s death under the applicable federal regulations. Id. at 227. The Court granted certification. 256 N.J. 519 (2024).

HELD: Preemption is not an issue here because the N.J.S.A. 3B:3-14 does not conflict with the federal regulations that govern U.S. savings bonds. Given that the DSA did not direct the disposition of the savings bonds, the bonds have no bearing 1 on Michael’s -- and later the Estate’s -- obligation to pay Jeanine $200,000, and the bonds’ value should not have been credited against that obligation. Pursuant to the DSA, the Estate must make whatever payments remain to Jeanine.

1. The Court reviews the federal regulations that govern Series EE bonds. 31 C.F.R. § 353.15 provides that “[s]avings bonds are not transferable . . . , except as specifically provided in these regulations.” One exception is that “[a] bond may be registered in the name of one individual payable on death to another.” Id. at .7(a)(3). If the bond owner dies and is survived by the beneficiary, “the beneficiary will be recognized as the sole and absolute owner of the bond.” Id. at .70(c)(1). The Treasury will not recognize judicial determinations that “impair[] the rights of survivorship conferred by these regulations upon a . . . beneficiary.” 31 C.F.R. § 353.20(a). However, the Treasury “will recognize a divorce decree that ratifies or confirms a property settlement agreement disposing of bonds,” and a savings bond may be reissued “to eliminate the name of one spouse” or to substitute one spouse’s name for the other pursuant to the divorce decree. Id. at .22(a). “[I]f established by valid, judicial proceedings,” the Treasury will also recognize claims “against an owner of a savings bond and conflicting claims of ownership of, or interest in, a bond between coowners or between the registered owner and the beneficiary.” Id. at .20(b). To establish the validity of a judicial proceeding, a party must submit “copies of the final judgment, decree, or court order.” Id. at .23(a). (pp. 12-14)

2. N.J.S.A. 3B:3-14 governs the revocation of probate and non-probate transfers by divorce. As relevant here, N.J.S.A. 3B:3-14(a)(1)(a) states that “[e]xcept as provided by the express terms of a governing instrument,” a divorce revokes any revocable “dispositions or appointment of property made by a divorced individual to his former spouse in a governing instrument.” N.J.S.A. 3B:3-14(b)(2) specifies that, for purposes of Section 3-14, “‘governing instrument’ means a governing instrument executed by the divorced individual before the divorce.” The general definitions section applicable to Title 3B defines a governing instrument to include “security registered in beneficiary form with the designation ‘pay on death.’” N.J.S.A. 3B:1- 1. And it defines “security” to include any “bond.” Id. at -2. (pp. 14-15)

3. The concept of preemption is derived from the Supremacy Clause of the United States Constitution, which establishes that federal law takes precedence over any state laws to the contrary. Conflict preemption occurs when state and federal obligations are inconsistent, making it impossible to comply with both. Here, New Jersey law does not conflict with federal survivorship regulations. N.J.S.A. 3B:3- 14(a) explicitly defers to “the express terms of a governing instrument,” and the pay- on-death U.S. savings bonds in dispute here, as regulated by the federal government that issued them, are the relevant “governing instruments,” see N.J.S.A. 3B:1-1 to - 2. Because N.J.S.A. 3B:3-14(a) does not supersede the terms of a governing instrument, and because the federal regulations governing the bonds at issue here 2 prevent the automatic revocation of a pay-on-death provision following a divorce, no such automatic revocation occurred under the exception set forth in Section 3-14(a). As the New Jersey statute incorporates and follows the relevant federal regulations, preemption does not apply here. (pp. 15-18)

4. Nor was Jeanine’s interest in the bonds revoked through the DSA. That agreement is silent regarding the bonds, and its broad catchall provision -- that “[a]ny marital asset not listed below belongs to the party who has it currently in their possession” -- simply confirms Jeanine’s ownership. The Estate is correct that the U.S. savings bonds, which were marital assets not listed in the DSA, belonged to Michael at the time the DSA was executed and during his life. The moment Michael passed away, however, Jeanine became the sole owner of the bonds as the pay-on- death beneficiary per 31 C.F.R. § 353.70(c)(1). The record contains no suggestion that Michael took any steps to have the bonds reissued in only his name or to provide evidence of the DSA to the Department of the Treasury as required by the regulations. The trial court’s holding, which impaired Jeanine’s right of survivorship as beneficiary of the bonds based on nothing more than its assumption that Michael likely intended to do so, is exactly the type of judicial determination the federal regulations do not allow. Thus, although the Court disagrees with the Appellate Division’s determination that Section 3-14(a) is preempted by federal law, the Appellate Division correctly reversed the trial court’s judgment. (pp. 18-21)

AFFIRMED AS MODIFIED.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, WAINER APTER, FASCIALE, and NORIEGA join in JUSTICE PIERRE-LOUIS’s opinion.

3 SUPREME COURT OF NEW JERSEY A-28 September Term 2023 088877

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In the Matter of the Estate of Michael D. Jones, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-the-estate-of-michael-d-jones-nj-2025.