In Egelhoff v. Egelhoff, 532 U.S. 141, 121 S. Ct. 1322, 1328, 149 L. Ed. 2d 264 (2001), David Egelhoff obtained a divorce but did not change the designation of his former wife as the beneficiary of a life insurance policy. Upon Egelhoff's death, his ERISA plan administrator paid the policy proceeds to his former wife. His children then sued her to recover those proceeds. The Egelhoff children relied on a state statute that revoked a designation of a spouse as the beneficiary of a life insurance policy upon divorce. The Supreme Court held that ERISA preempts state law in this regard. The Court reasoned that the state law was at odds with ERISA's directives that a plan administrator must make payments to the beneficiary designated by the plan participant: In particular, the Washington statute runs counter to ERISA's commands that a plan shall "specify the basis on which payments are made to and from the plan," 1102(b)(4), and that the fiduciary shall administer the plan "in accordance with the documents and instruments governing the plan," 1104(a)(1)(D), making payments to a "beneficiary" who is "designated by a participant, or by the terms of the plan." 1002(8). The Supreme Court further reasoned that one of the primary goals of ERISA is uniformity and that "uniformity is impossible, however, if plans are subject to different legal obligations in different States." The Court then concluded that uniformity was threatened because plan administrators could not rely on a beneficiary designation but would instead have to learn state laws. 61 The burden on administrators would be compounded when the employer, plan participant, and the participant's former spouse were each in a different state. The goals of ERISA would be undermined, the Court concluded: Requiring ERISA administrators to master the relevant laws of 50 States and to contend with litigation would undermine the congressional goal of "minimizing their administrative and financial burdens." . . . Differing state regulations affecting an ERISA plan's "system for processing claims and paying benefits" impose "precisely the burden that ERISA pre-emption was intended to avoid." The Court's determination that state law was preempted was unaffected by the fact that the plan administrator in Egelhoff had already paid the proceeds to David Egelhoff's former wife, and that the suit was against her, not the plan administrator. Nor was it an answer, the Supreme Court reasoned, that the state statute protected an administrator who made payments to a former spouse without actual knowledge that the marriage had been dissolved. First, an administrator faces the risk that it could be found to have actual knowledge of the divorce. Second, if the administrator awaited the results of litigation before making payment, the costs of delay, uncertainty, and litigation would ultimately be borne by the beneficiaries: "If they instead decide to await the results of litigation before paying benefits, they will simply transfer to the beneficiaries the costs of delay and uncertainty." The Supreme Court concluded that one of ERISA's purposes is efficient, low-cost administration of employee benefit plans, and that purpose would be frustrated: The dissent observes that the Washington statute permits a plan administrator to avoid resolving the dispute himself and to let courts or parties settle the matter. This observation only presents an example of how the costs of delay and uncertainty can be passed on to beneficiaries, thereby thwarting ERISA's objective of efficient plan administration. The Supreme Court was cognizant of the "presumption against pre-emption in areas of traditional state regulation such as family law." But the Court held "that presumption can be overcome where, as here, Congress has made clear its desire for pre-emption." The Supreme Court determined whether ERISA preempted a challenge to a statute that literally changed the terms of a plan document by automatically revoking the designation of a former spouse as a beneficiary. The plan administrator in Egelhoff thus had to determine the effect of the state statute before deciding whether to pay the named beneficiary. Id.