Ridgway v. Ridgway

In Ridgway v. Ridgway, 454 U.S. 46, 70 L. Ed. 2d 39, 102 S. Ct. 49 (1981), the facts indicated Army Sergeant Richard H. Ridgway ("Ridgway") was ordered by the courts of Maine, at the time of his divorce from wife April, to keep current insurance policies in force for the benefit of his three children. At the time of the divorce, Ridgway's life was insured under a policy for $ 20,000.00 issued by Prudential Insurance Company pursuant to the SGLIA, with April as beneficiary. Subsequently, Ridgway married his second wife, Donna Ridgway, and changed the policy's beneficiary designation, directing that it be paid as specified "by law." Under SGLIA, the serviceman can name a beneficiary, and if none is named, the proceeds go to his spouse at the time of his death. Id.; see 38 U.S.C.A. 1970(a) (1991). After Ridgway's death, April Ridgway instituted suit in Superior Court for Androscoggin County, Maine for a declaratory judgment that her children were entitled to the SGLI proceeds. Donna Ridgway also asserted a claim for the proceeds, whereupon April Ridgway cross-claimed, asking for a constructive trust on any proceeds paid to Donna Ridgway for the benefit of the Ridgway children. The Superior Court for Androscoggin County, Maine ruled in favor of Donna Ridgway, stating that a constructive trust on the SGLI proceeds would interfere with the operation of the SGLIA, running afoul of the Supremacy Clause of the United States Constitution. The Supreme Judicial Court of Maine reversed. The United States Supreme Court granted certiorari and reversed the Supreme Judicial Court of Maine, stating: 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. . . . "Congress has spoken with force and clarity in directing that the proceeds belong to the named beneficiary and no other." Ridgway, 454 U.S. at 56, 70 L. Ed. 2d at 48 (quoting Wissner v. Wissner, 338 U.S. 655, 94 L. Ed. 424, 70 S. Ct. 398 (1950)).