Ridgway v. Ridgway

454 U.S. 46, 102 S. Ct. 49, 70 L. Ed. 2d 39, 1981 U.S. LEXIS 143, 50 U.S.L.W. 4006

Opinions

Justice Blackmun

delivered the opinion of the Court.

This case presents the issue whether an insured serviceman’s beneficiary designation under a life policy issued pursuant to the Servicemen’s Group Life Insurance Act of 1965 (SGLIA), Pub. L. 89-214, 79 Stat. 880, prevails over a constructive trust imposed upon the policy proceeds by a state-court decree.

I — I

The Facts

Richard H. Ridgway was a career sergeant in the United States Army. April D. Ridgway was his wife. Richard and April were the parents of three children, Hayley, Laurie, and Brady, all minors. The Ridgways’ marriage, however, ended with a divorce granted by a Maine court on December 7, 1977. The state divorce judgment, entered on April’s complaint and apparently following property settlement negotiations, ordered Richard, among other things, to pay specified amounts monthly for the support of the three children. App. 13. It also ordered him

“to keep in force the life insurance policies on his life now outstanding for the benefit of the parties’ three children. If any of such insurance policies should subsequently be terminated for any reason, defendant shall immediately replace it with other life insurance of equal amount for the benefit of the children.” Id., at 14.

Sergeant Ridgway’s life was then insured under a $20,000 policy issued by Prudential Insurance Company of America pursuant to a group contract with the Administrator of Veterans’ Affairs. At the time of the Ridgways’ divorce, April was the designated beneficiary of that policy.

On March 28, 1978, less than four months after the divorce, Ridgway married his second wife, Donna, the individual petitioner here. Six days later, the sergeant, as insured, changed the policy’s beneficiary designation to one directing that its proceeds be paid as specified “by law.” This referred to the statutory order of beneficiary precedence set forth in 38 U. S. C. § 770(a). See also 38 CFR §9.16(i) (1980). Under that statutory prescription, the policy proceeds, in the event of Ridgway’s death, would be paid to his “widow,” that is, his “lawful spouse ... at the time of his death.” 38 U. S. C. § 765(7).

Sergeant Ridgway died on January 5, 1979. Donna survived him and was his lawful wife at the time of his death. Both April and Donna filed claims for the proceeds of the policy. April based her claim, which was on behalf of the children, on the divorce decree. Donna’s claim rested on the beneficiary designation and her status as Ridgway’s widow.

April thereafter instituted the present suit in the Superior Court for Androscoggin County, Me. As legal representative of the three minor children, she sued Prudential, seeking both to enjoin the payment of the policy proceeds to Donna, and to obtain a declaratory judgment that those proceeds were payable to the children. Donna joined the litigation and was aligned as a plaintiff asserting a claim to the proceeds. April then filed a cross-claim against Donna, praying for the imposition of a constructive trust, for the benefit of the children, on any policy proceeds paid to Donna. Prudential supported Donna’s position.

The Superior Court rejected April Ridgway’s claims. It acknowledged that the terms of the judgment of divorce and the beneficiary designation were inconsistent.¹ But it felt that the imposition of a constructive trust would interfere with the operation of the federal SGLIA, and that such a disposition would therefore run afoul of the Supremacy Clause, U. S. Const., Art. VI, cl. 2. App. 38-43.

On the ensuing appeal to the Supreme Judicial Court of Maine, the parties stipulated, inasmuch as the policy proceeds by that time had been deposited in court, that the sole issue was “[wjhether or not the presiding justice erred in ruling that, on the basis of the facts found, he could not impose a constructive trust on the proceeds of Sergeant Ridgway’s insurance.” Id., at 48. That court, sympathetic to April, vacated the Superior Court’s dismissal of her cross-claim, and remanded the case with directions to enter an order naming Donna as constructive trustee of the policy proceeds. The Court Clerk, who held the proceeds, was directed to pay them to April for and on behalf of the three children. Ridgway v. Prudential Ins. Co. of America, 419 A. 2d 1030, 1035 (1980).

We granted certiorari, 450 U. S. 979 (1981), to review the important issue presented by the case.

II

The Statutory Background

In order to make life insurance coverage available to members of the uniformed services on active duty, particularly in combat zones, Congress in 1965 enacted the SGLIA. See H. R. Rep. No. 1003, 89th Cong., 1st Sess., 7 (1965). The impetus for the legislation was the escalating level of hostilities and casualties in the then ongoing Vietnam conflict; this had prompted private commercial insurers to restrict coverage for service members.² See 111 Cong. Rec. 24339 (1965) (remarks of Rep. Teague, Chairman of the House Committee on Veterans’ Affairs); see also S. Rep. No. 619, 89th Cong., 1st Sess., 3 (1965). The earlier program of federally sponsored life insurance for service members, see National Service Life Insurance Act of 1940, 54 Stat. 1008, and National Service Life Insurance Act of 1958, as amended, 38 U. S. C. § 701 et seq. (NSLIA), placed in effect shortly before the involvement of this country in World War II, had been allowed to lapse after the end of the Korean hostilities when commercial insurance generally became available to service members.³ Accordingly, NSLIA coverage could not be obtained by many service members on active duty in 1965. See 111 Cong. Rec. 24339 (1965) (remarks of Rep. Teague).

Although its purposes and provisions resemble those of the NSLIA in many respects, the SGLIA differs from the predecessor program in that it directs the Administrator of Veterans’ Affairs to purchase coverage from one or more qualified commercial insurers instead of offering coverage by the United States itself. See 38 U. S. C. §766. Thus, under the SGLIA, the Government is the policyholder, rather than the insurer. The Administrator has contracted with petitioner Prudential Insurance Company of America, which now serves as the primary insurer under the SGLIA and which operates, under Veterans’ Administration supervision and pursuant to 38 U. S. C. § 766(b), the Office of Servicemen’s Group Life Insurance in Newark, N. J.

The SGLIA initially provided insurance only for members serving in specified services. 79 Stat. 880. The maximum coverage allowed was then $10,000. Id., at 881. Since 1965, however, statutory changes have expanded both eligibility for coverage and the amount of insurance available.⁴ The program is operated on a presumptive enrollment basis; coverage is provided automatically and premiums are withheld from the service member’s pay, unless the insurance is expressly declined or is terminated by written election. 38 U. S. C. §§ 767(a) and 769.⁵

In order to make the insurance available through a commercial carrier at a reasonable rate, notwithstanding the special mortality risks that service members often must assume, Congress undertook to subsidize the program. See S. Rep. No. 91-398, p. 2 (1969). A sum representing the extra premium for special mortality risks is periodically deposited by the United States into a revolving fund that is used to pay premiums on the master policy. See 38 U. S. C. §§ 769(b) and (d)(1). The fund otherwise is derived primarily from deductions withheld from service members’ pay. §§ 769(a)(1) and (d)(1). Accordingly, depending upon the conditions faced by service members at any given time, the program may be financed in part with federal funds. See S. Rep. No. 91-398, at 2.

The SGLIA establishes a specified “order of precedence,” 38 U. S. C. § 770(a), for policy beneficiaries. By this statutory provision, the proceeds of a policy are paid first to such “beneficiary or beneficiaries as the member . . . may have designated by [an appropriately filed] writing received prior to death.” If there be no such designated beneficiary, the proceeds go to the widow or widower of the service member or, if there also be no widow or widower, “to the child or children of such member . . . and descendants of deceased children by representation.” Parents, and then the representative of the insured’s estate (an obvious bow at this point in the direction of state law), are next in order. Ibid. See also 38 CFR §9.16(i) (1980).

In 1970, by Pub. L. 91-291, §5, 84 Stat. 330, Congress added an anti-attachment provision. With certain exceptions not applicable here, this provision shields payments made under § 770(a) “from taxation” and from “claims of creditors,” and states that the payments “shall not be liable to attachment, levy, or seizure by or under any legal or equitable process whatever, either before or after receipt by the beneficiary.” § 770(g).

Pursuant to his general rulemaking authority over veterans’ programs, § 210(c)(1), the Administrator has promulgated regulations implementing the SGLIA. These provide that the insured “may designate any person, firm, corporation or legal entity” as a policy beneficiary, and any such “designation or change of beneficiary . . . will take effect only if it is in writing, signed by the insured and received [by the appropriate office] prior to the death of the insured.” 38 CFR §§ 9.16(a) and (d) (1980). A change of beneficiary “may be made at any time and without the knowledge or consent of the previous beneficiary.” § 9.16(e). And “[n]o change or cancellation of beneficiary ... in a last will or testament, or in any other document shall have any force or effect unless such change is received by the appropriate office.” § 9.16(f).

l — l l — l l — l

The foregoing description of the statutory plan adopted by Congress, and implemented by the Administrator’s regulations, demonstrates the pervasive and detailed characteristics of the congressional specifications. The obvious and stated concern of Congress was to provide coverage for the member, no matter how hazardous the duty, and thus protection for the member’s designated beneficiaries. The legislation itself says nothing about contrary dictates of state law or state judgments.

The Supreme Judicial Court of Maine, however, concluded that the order of beneficiary precedence set forth in 38 U. S. C. § 770(a) “does not reflect any federal interest in permitting a serviceman to evade the responsibility to provide for his minor children imposed both by virtue of his voluntary agreement and by the express provision of a valid state court decree.” 419 A. 2d, at 1033. That court further concluded that the anti-attachment provision, § 770(g), “has no application to the instant case since its purpose is to protect the proceeds of the insurance from the claims of creditors.” It pointed out that it was concerned “not with the claim of a creditor but with the claims of minor children who assert an equitable interest in the proceeds arising from their deceased father’s voluntary agreement and a valid judicial decree.” Thus, it said, the accomplishment of the objectives of the federal statute “is neither obstructed nor interfered with by imposing a constructive trust on the insurance proceeds.” Ibid.

We forthwith acknowledge, of course, that this Court’s “only power over state judgments is to correct them to the extent that they incorrectly adjudge federal rights.” Herb v. Pitcairn, 324 U. S. 117, 125-126 (1945). It follows that the decision of the Supreme Judicial Court of Maine is subject to disturbance here only to the extent that it fails to honor federal rights and duties.

Notwithstanding the limited application of federal law in the field of domestic relations generally, see McCarty v. McCarty, 453 U. S. 210, 220 (1981); Hisquierdo v. Hisquierdo, 439 U. S. 572, 581 (1979); In re Burrus, 136 U. S. 586, 593-594 (1890), this Court, even in that area, has not hesitated to protect, under the Supremacy Clause, rights and expectancies established by federal law against the operation of state law, or to prevent the frustration and erosion of the congressional policy embodied in the federal rights. See McCarty v. McCarty, supra; Hisquierdo v. Hisquierdo, supra; Free v. Bland, 369 U. S. 663 (1962); Wissner v. Wissner, 338 U. S. 655 (1950); McCune v. Essig, 199 U. S. 382 (1905). Cf. Yiatchos v. Yiatchos, 376 U. S. 306, 309 (1964). While “[sjtate family and family-property law must do ‘major damage’ to ‘clear and substantial’ federal interests before the Supremacy Clause will demand that state law be overridden,” Hisquierdo, 439 U. S., at 581, with references to United States v. Yazell, 382 U. S. 341, 352 (1966), “[t]he relative importance to the State of its own law is not material when there is a conflict with a valid federal law, for the Framers of our Constitution provided that the federal law must prevail.” Free v. Bland, 369 U. S., at 666. See also Gibbons v. Ogden, 9 Wheat. 1, 210-211 (1824). And, specifically, a state divorce decree, like other law governing the economic aspects of domestic relations, must give way to clearly conflicting federal enactments. McCarty v. McCarty, supra; Hisquierdo v. Hisquierdo, supra. That principle is but the necessary consequence of the Supremacy Clause of our National Constitution.

In Wissner v. Wissner, supra, an insured under an NSLIA policy named his parents as beneficiaries. Upon his death, the serviceman’s widow claimed community property rights in the policy proceeds. The NSLIA specifically provided that the insured had the right to designate and to change the beneficiary. It also had an anti-attachment clause. Despite these provisions, a California court held that the policy proceeds were community property, and it ordered half the proceeds paid to the widow. This Court reversed, noting that “Congress has spoken with force and clarity in directing that the proceeds belong to the named beneficiary and no other.” 338 U. S., at 658. Further, “the judgment below nullifies the soldier’s choice and frustrates the deliberate purpose of Congress. It cannot stand.” Id., at 659. And the diversion, as directed by the state court, of future payments to be received by the beneficiary would be a “seizure” prohibited by the anti-attachment provision. Ibid. These are strong words and a positive ruling.

The same approach has been followed in later cases: Free v. Bland, supra, concerning the right of survivorship in United States Savings Bonds issued in co-ownership form; Hisquierdo v. Hisquierdo, supra, involving the Railroad Retirement Act of 1974, 45 U. S. C. §231 et seq.; and McCarty v. McCarty, supra, concerning military retired pay.

The present case, we feel, is controlled by Wissner. Under §§ 717(a) and 770(a) of the SGLIA, just as under § 602(g) of the predecessor NSLIA, 54 Stat. 1010, at issue in Wissner, the insured service member possesses the right freely to designate the beneficiary and to alter that choice at any time by communicating the decision in writing to the proper office. 338 U. S., at 658. Here, as there, it appropriately may be said: “Congress has spoken with force and clarity in directing that the proceeds belong to the named beneficiary and no other.”

There can be no doubt that Congress was aware of the breadth of the freedom of choice accorded the service member under the SGLIA. The pertinent House Report stated flatly: “The serviceman may designate any person as a beneficiary,” H. R. Rep. No. 1003, 89th Cong., 1st Sess., 7 (1965), and the point was emphasized on the floor of the House by Representative Everett: “This bill permits you to leave your insurance to your church, to your college, to your best friend. The beneficiary provision is wide open under this option.” Ill Cong. Rec. 24341 (1965). Thus, the Maine court’s analysis is inconsistent both with the language of the Act and with its legislative history.⁶

Neither respondents nor the Supreme Judicial Court of Maine has questioned the authority of Congress to control payment of the proceeds of SGLIA policies. Indeed, this Court observed in Wissner:

“Possession of government insurance, payable to the relative of his choice, might well directly enhance the morale of the serviceman. The exemption provision is his guarantee of the complete and full performance of the contract to the exclusion of conflicting claims. The end is a legitimate one within the congressional powers over national defense, and the means are adapted to the chosen end.” 388 U. S., at 660-661.

The federal interest is especially strong because a substantial share of the proceeds of an SGLIA policy may be attributable to general tax revenues.

There are, to be sure, some small differences between the SGLIA and the predecessor NSLIA. In the provision granting the service member the right to designate the beneficiary, the words “at all times” appear in the earlier Act, 38 U. S. C. § 717(a), but not in the later one, 38 U. S. C. § 770(a), and the right to change the beneficiary “without the consent” of the one presently named is spelled out in § 717(a) but not in § 770(a). But the later Act’s unqualified directive to pay the proceeds to the properly designated beneficiary clearly suggests that no different result was intended by Congress. And any possible ambiguity was eliminated by the Administrator’s regulations that provide that a “change of beneficiary may be made at any time and without the knowledge or consent of the previous beneficiary.” 38 CFR §9.16(e) (1980). There has been no suggestion that these regulations are unreasonable, unauthorized, or inconsistent with the SGLIA, and such a suggestion would not be supportable.⁷ See Whirlpool Corp. v. Marshall, 445 U. S. 1, 11-13 (1980); Udall v. Tallman, 380 U. S. 1, 16 (1965).

Yiatchos v. Yiatchos, 376 U. S. 306 (1964), relied on by the respondents, but not cited by the Maine court, does not stand to the contrary. In Yiatchos, the Court considered a question left open in Free v. Bland, 369 U. S., at 670-671, namely, the “scope and application” of the doctrine of fraud as an exception “to the regulatory imperative.” 376 U. S., at 307. There, the decedent Yiatchos, a resident of a community property State, purchased United States Savings Bonds with community funds and had them issued in the name of the decedent but payable on his death to his brother. The state court held that this purchase “was in fraud of the rights” of the surviving wife, as “a void endeavor to divest the wife of any interest in her own property.” In re Yiatchos’ Estate, 60 Wash. 2d 179, 181-182, 373 P. 2d 125, 127 (1962). This Court agreed that the bonds could “not be used as a device to deprive the widow of property rights which she enjoys under Washington law.” 376 U. S., at 309. But because the named beneficiary was entitled to the bonds “unless his deceased brother committed fraud or breach of trust tantamount to fraud” by wrongfully disposing of the wife’s property, ibid., the case was remanded to give the widow an opportunity to demonstrate that she had not consented to or ratified the purchase and registration of the bonds. The remand was also for the determination, under state law, whether the widow had an interest in the community’s specific assets, or only a half interest in the estate generally.

Here, in contrast, Sergeant Ridgway’s conduct did not amount to breach of trust or conversion of another’s property. A careful reading of the complaint and the amended complaint, App. 11 and 24, in this case reveals no allegation of fraud or breach of trust. And we are not inclined to provide or infer such an allegation when a case comes to us, as this one does, with the record indicating nothing more than a breach of contract on the part of the deceased service member. Indeed, to say that this type of conduct constitutes constructive fraud would be to open the policy proceeds to a suit by any commercial creditor, a result that would render § 770(g) nugatory. As the trial court intimated, respondents may have a claim against the insured’s estate for that breach; the record does not disclose whether a claim of that kind would be collectible.⁸

There is, finally, a fundamental distinction between respondents’ asserted interests in the SGLIA policy proceeds and the community property concepts at issue in Yiatchos. Federal law and federal regulations bestow upon the service member an absolute right to designate the policy beneficiary. That right is personal to the member alone. It is not a shared asset subject to the interests of another, as is community property. Yiatchos had imposed his will upon property in which his wife had a distinct vested community interest. In contrast, only Sergeant Ridgway had the power to create and change a beneficiary interest in his SGLIA insurance. By exercising that power, he hardly can be said to have committed fraud.

We conclude, therefore, that the controlling provisions of the SGLIA prevail over and displace inconsistent state law.⁹

IV

The imposition of a constructive trust upon the insurance proceeds is also inconsistent with the anti-attachment provision, 38 U. S. C. § 770(g), of the SGLIA. In Wissner, 338 U. S., at 659, this Court invoked the identical anti-attachment provision of the NSLIA as an independent ground for the result reached in that case. The Court rejected, as it did so, id., at 663-664, the dissent’s argument that “Congress was interested in protecting [the fund], not the beneficiary,” which parallels respondents’ argument here in favor of creating a constructive trust after the proceeds have been received by the beneficiary. Any diversion of the proceeds of Sergeant Ridgway’s SGLIA policy by means of a court-imposed constructive trust would therefore operate as a forbidden “seizure” of those proceeds.

The Maine court attempted to limit the reach of § 770(g), as has been noted above, on the theory that the purpose of the anti-attachment provision was to protect the policy proceeds from the claims of creditors, and that the provision has no application to minor children asserting equitable interests. 419 A. 2d, at 1033. This contention, however, fails to give effect to the unqualified sweep of the federal statute. Section 770(g), in addition to exempting the policy proceeds “from the claims of creditors,” prohibits, in the broadest of terms, any “attachment, levy, or seizure by or under any legal or equitable process whatever,” whether accomplished “either before or after receipt by the beneficiary.” The reading adopted by the Maine court renders the bulk of the quoted statutory text extraneous. What was said of the statute under consideration in Hisquierdo, supra, is applicable without qualification here:

“Like anti-attachment provisions generally [citing Wissuer], it ensures that the benefits actually reach the beneficiary. It pre-empts all state law that stands in its way. It protects the benefits from legal process ‘[notwithstanding any other law... of any State’. ... It prevents the vagaries of state law from disrupting the national scheme, and guarantees a national uniformity that enhances the effectiveness of congressional policy.” 439 U. S., at 584.¹⁰

We find nothing to indicate that Congress intended to exempt claims based on property settlement agreements from the strong language of the anti-attachment provision.¹¹

V

We recognize that this unpalatable case suggests certain “equities” in favor of the respondent minor children and their mother. Sergeant Ridgway did have specific obligations to the children that were imposed by the 1977 divorce judgment of the Maine court. Those obligations not only concerned life insurance “now outstanding” for the benefit of the children, but also extended to their support, to clothing, to “medical, dental, and optical expense,” and to certain loans and other indebtedness. App. 13-15. Ridgway, instead, chose to name his then new wife as beneficiary of his SGLIA policy.¹²

A result of this kind, of course, may be avoided if Congress chooses to avoid it. It is within Congress’ power. Thus far, however, Congress has insulated the proceeds of SGLIA insurance from attack or seizure by any claimant other than the beneficiary designated by the insured or the one first in line under the statutory order of precedence. That is Congress’ choice. It remains effective until legislation providing otherwise is enacted.

The judgment of the Supreme Judicial Court of Maine is

Reversed.

Justice O’Connor took no part in the consideration or decision of this case.

1 The Superior Court observed that the “agreement embodied in the divorce decree is valid,” and it opined that the decree “would appear to give [April] a cause of action, on behalf of her children, against the estate of her former husband,” App. 42, citing Stratton v. Servicemen’s Group Life Ins. Co., 422 F. Supp. 1119 (SD Iowa 1976). See id,., at 1122.

2 The very title of the Act recited that it was “to provide special indemnity insurance for members of the Armed Forces serving in combat zones, and for other purposes.” 79 Stat. 880.

3 A similar and still earlier program of United States Government, or War Risk, Insurance, was in effect for the World War I period. War Risk Insurance Act of Oct. 6, 1917, § 400, 40 Stat. 409. See United States v. Williams, 302 U. S. 46 (1937).

4 See Pub. L. 91-291, §§ 1 and 2, 84 Stat. 326-327; Pub. L. 92-315, 86 Stat. 227; Pub. L. 93-289, 88 Stat. 165, 166, 169.

5 The Solicitor General states that 99.6% of all active duty personnel and 97.9% of the Ready Reservists are enrolled in the program. Brief for United States as Amicus Curiae 5. See also S. Rep. No. 91-398, p. 2 (1969).

6 In its consideration of the purpose of the SGLIA, the Supreme Judicial Court of Maine, Ridgway v. Prudential Ins. Co. of America, 419 A. 2d 1030, 1032-1033 (1980), relied upon a statement made in 1965 by the then Administrator of Veterans’ Affairs. The statement is appended to H. R. Rep. No. 1003, 89th Cong., 1st Sess., 15-17 (1965). In our view, however, the remarks cannot be used to read the choice-of-beneficiary provision out of the Act. In context, it is plain that the statement was not intended to serve as an exhaustive list of congressional purposes; it merely identified some of the problems in the existing law that were addressed by the pending legislation.

7 Justice Stevens suggests that the “interest in permitting a serviceman to designate the beneficiary of his insurance policy [expressed in § 770(a)] is not compromised” by the Maine court’s decision. Post, at 80. While that may or may not be true as a matter of policy, the statute expressly commands that SGLIA proceeds go to the beneficiary or beneficiaries designated by the service member. And the implementing regulations expressly command that a “change of beneficiary . . . will take effect only if it is in writing, signed by the insured and received [by the appropriate office] prior to the death of the insured,” 38 CFR § 9.16(d) (1980); “[n]o change or cancellation of beneficiary ... in a last will or testament, or in any other document shall have any force or effect unless such change is received by the appropriate office.” 5 9.16(f). Yet Justice Stevens points to nothing in the language or history of the statute and regulations which suggests that Congress and the Administrator did not mean what they said.

8 Justice Powell looks to Yiatchos v. Yiatchos, 376 U. S. 306 (1964), and Free v. Bland, 369 U. S. 663 (1962), in concluding that “the principle of not allowing federal pre-emption to shield fraud or breach of trust” is applicable here. Post, at 64, n. 1. Those cases, however, were concerned with a particular type of fraudulent behavior: attempts “to divest the wife of any interest in her own property,” In re Yiatchos’ Estate, 60 Wash. 2d 179, 181-182, 373 P. 2d 125, 127 (1962) (emphasis added); see Yiatchos, 376 U. S., at 309, which grew out of “fraud or a breach of trust tantamount thereto on the part of a husband while acting in his capacity as manager of the general community property.” Free v. Bland, 369 U. S., at 670. In this case, by way of contrast, Sergeant Ridgway misdirected property over which he had exclusive control. In doing so, of course, he deprived the respondents of benefits to which they were entitled under state law. But that is precisely what transpired in Wissner v. Wissner, 338 U. S. 655 (1950). Indeed, Free endorsed the Wissner holding, noting that “[t]here the Congress made clear its intent to allow a serviceman to select the beneficiary of his own government life insurance policy regardless of state law, even when it was likely that the husband intended to deprive his wife of a right to share in his life insurance proceeds, a right guaranteed by state law.” 369 U. S., at 670. We are unable to distinguish the cases.

9 We need not presently address the legal aspects of extreme fact situations or of instances where the beneficiary has obtained the proceeds through fraudulent or illegal means as, for example, where the named beneficiary murders the insured service member. See Shoemaker v. Shoemaker, 263 F. 2d 931 (CA6 1959). Our ruling on a situation of that kind is reserved for another day.

10 Burgess v. Murray, 194 F. 2d 131 (CA5 1952), and Voelkel v. Tohulka, 236 Ind. 588, 141 N. E. 2d 344, cert. denied, 355 U. S. 891 (1957), relied on by the respondents but not cited by the Maine court, are not helpful. To be sure, in each of those NSLIA cases, a constructive trust was imposed on the policy proceeds. This, however, was done to further the service member’s dispositive intent. Here Sergeant Ridgway apparently intended to favor Donna as his surviving spouse. In any event, the regulations implementing the SGLIA’s beneficiary designation requirements are stricter than the corresponding regulations promulgated under the NSLIA. Compare 38 CFR §§ 8.46 and 8.47 (1980) (NSLIA) with 38 CFR §§ 9.16(d) and 9.16(f) (1980) (SGLIA).

11 Justice Powell suggests, without supporting citation, that the anti-attachment provision is inapplicable in this case because of “the special nature of the parental legal duty,” noting that “[f]amilial obligations are not merely commercial.” Post, at 70, 68. Again, Wissner answers this objection. There, the claimant was the decedent’s widow, not a commercial creditor. Her action was grounded in the law of community property; the Court explicitly conceded that “[tjhere are . . . support aspects to the community property principle, and in some cases they may be of considerable importance.” 338 U. S., at 660, n. 4. The Court nevertheless struck down a state-court judgment in the widow’s favor as being “in flat conflict” with the NSLIA’s anti-attachment provision. Id., at 659. We see no significant difference between the community property interest at issue in Wissner and the property settlement giving rise to the instant action.

Justice Stevens, meanwhile, argues that “it is most unlikely that Congress intended § 770(g) to operate as a bar to claims advanced by an insured’s dependents for support,” post, at 74; he reasons that “[pjrior to the decision of this Court in Wissner, a number of courts had held that statutory ‘spendthrift’ provisions did not bar a claim for alimony or support,” ibid., and “there is nothing . . . that evidences an intent by Congress to repudiate this distinction between commercial and family obligations.” Post, at 78. And he suggests that “[t]he federal interest incorporated within exemption statutes is an interest in preventing federally supported benefits from satisfying claims of commercial creditors.” Post, at 78-79.

While these are attractive arguments, neither of them survives close scrutiny. The more recent decisions, many involving facts almost identical to those before us, are virtually unanimous in concluding that the NSLIA anti-attachment provision overrides the contrary dictates of state family law. E. g., Hoffman v. United States, 391 F. 2d 195 (CA9 1968) (anti-attachment provision overrides property settlement incorporated in divorce decree); Kimball v. United States, 304 F. 2d 864 (CA6 1962) (same); Eldin v. United States, 157 F. Supp. 34 (SD Ill. 1957) (same); Williams v. Williams, 255 N. C. 315, 121 S. E. 2d 536 (1961) (same); Fleming v. Smith, 69 Wash. 2d 277, 284, 418 P. 2d 147, 151 (1966) (same). Cf. United States v. Donall, 466 F. 2d 1246 (CA6 1972); Taylor v. United States, 459 F. 2d 1007 (CA9), cert. denied, 409 U. S. 967 (1972); Suydam v. United States, 131 U. S. App. D. C. 352, 404 F. 2d 1329 (1968); Fitzstephens v. United States, 189 F. Supp. 919 (Wyo. 1960); Heifner v. Soderstrom, 134 F. Supp. 174 (ND Iowa 1955). And it was against the background of these decisions that, in 1970, Congress enacted the SGLIA’s anti-attachment provision — using language identical to that found in the NSLIA. Presumably, then, Congress did not intend to write into the statute the distinction made by Justice Stevens. And our view, we believe, most closely accords with the purpose of anti-attachment provisions like the one before us: they “ensur[e] that the benefits actually reach the beneficiary.” Hisquierdo v. Hisquierdo, 439 U. S. 572, 584 (1979).

12 Respondents, in their brief and in oral argument, speak of the “unjust enrichment” of Donna Ridgway. The suggestion is not persuasive. The record discloses no wrong on Donna’s part. She was, after all, the insured’s lawful wife at the time of his death, and it is possible that depriving her of the proceeds would be as inequitable as any other result. We intimate no view as to whether wrongdoing by the named beneficiary would change the outcome. See n. 9, supra.