In re Estate of Egelhoff
In In re Estate of Egelhoff, 139 Wn.2d 557, 989 P.2d 80 (1999), the court defined direct preemption as applying where "the state law has a sufficient 'connection with' an ERISA plan to compel preemption." However, the Egelhoff court further stated, "A direct preemption analysis is required when a state law . . . directly or indirectly invades the core functions of ERISA regulation. . . ." In re Estate of Egelhoff, supra, 989 P.2d at 89.
Thus, the Egelhoff court's definition of "direct preemption" combined the principles of direct and statutory preemption.