2018 Contract Clause Case
2018 United States Supreme Court case
Sveen v. Melin |
---|
|
Argued March 19, 2018 Decided June 11, 2018 |
---|
Full case name | Ashley Sveen, et al., v. Kaye Melin |
---|
Docket no. | 16-1432 |
---|
Citations | 584 U.S. (more) |
---|
Argument | https://www.oyez.org/cases/2017/16-1432 |
---|
Decision | Opinion |
---|
Court membership |
---|
- Chief Justice
- John Roberts
- Associate Justices
- Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer Samuel Alito · Sonia Sotomayor Elena Kagan · Neil Gorsuch |
Case opinions |
---|
Majority | Kagan, joined by Roberts, Kennedy, Thomas, Ginsburg, Breyer, Alito, Sotomayor |
---|
Dissent | Gorsuch |
---|
Sveen v. Melin, 584 U.S. ___ (2018), was a case in which the U.S. Supreme Court decided whether a Minnesota law violated the Contract Clause of the Constitution of the United States.
Background
In 1997, Mark Sveen and Kaye Melin got married and the next year, Sveen purchased a life insurance policy. Melin was named as the primary beneficiary on this policy, and two of his children from a prior marriage were named as contingent beneficiaries. Sveen and Melin divorced in 2007 but the family court made no mention of the insurance policy. Sveen died in 2011,[1] and a dispute developed between Melin and Sveen's children as to which of them could collect on his policy.[2]
According to a 2002 Minnesota law, "the dissolution or annulment of a marriage revokes any revocable[ ] disposition, beneficiary designation, or appointment of property made by an individual to the individual’s former spouse in a governing instrument,"[3] where a governing instrument is defined to include insurance policies. This meant that in the event of a divorce, one partner would be removed from the other's policies as a beneficiary and vice-versa. Sveen's children claimed that under this law, since their father had not explicitly sought to keep Melin on as his primary beneficiary, they should receive the death benefit.
Article 1, Section 10, Clause 2 of the Constitution, more colloquially known as the Contract Clause, says that, "No state shall pass any Law impairing the obligation of contracts." Melin argued that since the Minnesota law did not exist when her ex-husband purchased his insurance policy, to allow it to alter the terms of that policy later would be a violation of the Constitution.[4]
The District Court ruled in favor of the Sveens but the Eight Circuit reversed on appeal.
Supreme Court
The Court reversed the Appeals court ruling in an 8-1 decision with the majority decision authored by Associate Justice Elena Kagan.
Majority opinion
Kagan writes that in approaching Contract Clause cases, the court typically applies a two-step test. First, the court asks a threshold question as to whether the state law has "operated as a substantial impairment of a contractual relationship."[1] If the court finds that there is a substantial impairment, they then move on to the second part of the test which asks whether the law is an “appropriate” and “reasonable” way to advance “a significant and legitimate public purpose.”[1]
Kagan says that there are three reasons to stop after the first step and rule against Melin.
First, the law purports to support the policy holder's intent and further, rather than impair it because "most divorcees do not aspire to enrich their former partners."[1]
Second, the law doesn't disturb a policy holder's expectations because it is well within the power of divorce courts to revoke beneficiary status upon the dissolution of a marriage. Kagan's much broader argument to this point is that during a divorce all assets, homes, cars, and yes, insurance policies, are "up for grabs,"[1] and as such Melin has no reliance interest in remaining the primary beneficiary on her ex-husband's policy.
Third, if Sveen had so wished, he could have easily prevented this default rule from removing his ex-wife from his policy
Dissenting opinion
Associate Justice Neil Gorsuch was the sole dissenter in this case.
Gorsuch dissents by arguing that the retroactive application of the Minnesota Law violates the Contract Clause. First, he argues that the changing of beneficiaries in such a retroactive manner is a substantial impairment on the policy holder. Second, he writes that Minnesota could have used a much less intrusive method of reaching their goal such as requiring the divorce court to confirm beneficiary designation before the dissolution is finalized.
He also argues that the majority's decision introduces a paradox. The majority upheld the law partly on the basis that it could be easily undone, Gorsuch writes, "yet the Court just finished telling us the statute is justified because most policyholders neglect their beneficiary designations after divorce. Both claims cannot be true."[5]
References
- ^ a b c d e Kagan, Elena (June 11, 2018). "Sveen v. Melin" (PDF). supremecourt.gov. Archived (PDF) from the original on October 15, 2022. Retrieved July 26, 2022.
- ^ Mitchell, Thomas (June 20, 2018). "Can a Nevada law pass constitutional muster?". Elko Daily Free Press. Elko, Nevada. pp. A7. Archived from the original on April 22, 2023. Retrieved April 16, 2023.
- ^ Revisor of Statutes, MN (2002). "524.2-804 REVOCATION BY DISSOLUTION OF MARRIAGE; NO REVOCATION BY OTHER CHANGES OF CIRCUMSTANCES". Archived from the original on July 27, 2022. Retrieved July 26, 2022.
- ^ Doolin, Elizabeth; Wall, Julie; Jeffery, Joseph; Terrizzi, Victor (2020). "Recent Developments in Health Insurance, Life Insurance, and Disability Insurance Law". Tort Trial & Insurance Practice Law Journal. 55 (2): 323–371 – via EBSCO Host.
- ^ Gorsuch, Neil (June 11, 2018). "Sveen v. Melin" (PDF). Supremecourt.gov. Archived (PDF) from the original on October 15, 2022. Retrieved July 26, 2022.
Enumeration Clause of Section II |
---|
|
|
Qualifications Clauses of Sections II and III |
---|
|
|
Elections Clause of Section IV |
---|
|
|
|
|
|
|
|
---|
Dormant Commerce Clause | - Brown v. Maryland (1827)
- Willson v. Black-Bird Creek Marsh Co. (1829)
- Cooley v. Board of Wardens (1852)
- Wabash, St. Louis & Pacific Railway Co. v. Illinois (1886)
- Swift & Co. v. United States (1905)
- George W. Bush & Sons Co. v. Malloy (1925)
- Baldwin v. G.A.F. Seelig, Inc. (1935)
- Edwards v. California (1941)
- Southern Pacific Co. v. Arizona (1945)
- Dean Milk Co. v. City of Madison (1951)
- Miller Bros. Co. v. Maryland (1954)
- Bibb v. Navajo Freight Lines, Inc. (1959)
- National Bellas Hess v. Illinois (1967)
- Pike v. Bruce Church, Inc. (1970)
- Hughes v. Alexandria Scrap Corp. (1976)
- Complete Auto Transit, Inc. v. Brady (1977)
- Hunt v. Washington State Apple Advertising Commission (1977)
- City of Philadelphia v. New Jersey (1978)
- Exxon Corp. v. Governor of Maryland (1978)
- Reeves, Inc. v. Stake (1980)
- Kassel v. Consolidated Freightways Corp. (1981)
- Sporhase v. Nebraska ex rel. Douglas (1982)
- White v. Mass. Council of Construction Employers (1983)
- South-Central Timber Development, Inc. v. Wunnicke (1984)
- Maine v. Taylor (1986)
- Healy v. Beer Institute, Inc. (1989)
- Quill Corp. v. North Dakota (1992)
- Chemical Waste Management, Inc. v. Hunt (1992)
- Oregon Waste Systems, Inc. v. Department of Environmental Quality of Oregon (1994)
- C&A Carbone, Inc. v. Town of Clarkstown (1994)
- West Lynn Creamery, Inc. v. Healy (1994)
- Granholm v. Heald (2005)
- United Haulers Ass'n v. Oneida-Herkimer Solid Waste Management Authority (2007)
- Department of Revenue of Kentucky v. Davis (2008)
- Comptroller of the Treasury of Maryland v. Wynne (2015)
- South Dakota v. Wayfair, Inc. (2018)
- Tennessee Wine and Spirits Retailers Assn. v. Thomas (2019)
- National Pork Producers Council v. Ross (2023)
|
---|
Others | |
---|
|
|
|
|
---|
Copyright Act of 1790 | |
---|
Patent Act of 1793 | |
---|
Patent infringement case law | |
---|
Patentability case law | |
---|
Copyright Act of 1831 | |
---|
Copyright Act of 1870 | |
---|
Sherman Antitrust Act of 1890 | |
---|
International Copyright Act of 1891 | |
---|
Copyright Act of 1909 | |
---|
Patent misuse case law | |
---|
Clayton Antitrust Act of 1914 | |
---|
Lanham Act | - Inwood Laboratories, Inc. v. Ives Laboratories, Inc. (1982)
- San Francisco Arts & Athletics, Inc. v. United States Olympic Committee (1987)
- Two Pesos, Inc. v. Taco Cabana, Inc. (1992)
- Qualitex Co. v. Jacobson Products Co. (1995)
- College Savings Bank v. Florida Prepaid Postsecondary Education Expense Board (1999)
- Cooper Industries, Inc. v. Leatherman Tool Group, Inc. (2001)
- TrafFix Devices, Inc. v. Marketing Displays, Inc. (2001)
- Dastar Corp. v. Twentieth Century Fox Film Corp. (2003)
- Moseley v. V Secret Catalogue, Inc. (2003)
- Lexmark International, Inc. v. Static Control Components, Inc. (2014)
- POM Wonderful LLC v. Coca-Cola Co. (2014)
- Matal v. Tam (2017)
- Iancu v. Brunetti (2019)
- Romag Fasteners, Inc. v. Fossil, Inc. (2020)
|
---|
Copyright Act of 1976 | - Zacchini v. Scripps-Howard Broadcasting Co. (1977)
- Sony Corp. of America v. Universal City Studios, Inc. (1984)
- Mills Music, Inc. v. Snyder (1985)
- Harper & Row v. Nation Enterprises (1985)
- Community for Creative Non-Violence v. Reid (1989)
- Stewart v. Abend (1990)
- Feist Publications, Inc., v. Rural Telephone Service Co. (1991)
- Fogerty v. Fantasy, Inc. (1994)
- Campbell v. Acuff-Rose Music, Inc. (1994)
- Lotus Dev. Corp. v. Borland Int'l, Inc. (1996)
- Quality King Distributors Inc., v. L'anza Research International Inc. (1998)
- Feltner v. Columbia Pictures Television, Inc. (1998)
- New York Times Co. v. Tasini (2001)
- Eldred v. Ashcroft (2003)
- MGM Studios, Inc. v. Grokster, Ltd. (2005)
- Reed Elsevier, Inc. v. Muchnick (2010)
- Golan v. Holder (2012)
- Kirtsaeng v. John Wiley & Sons, Inc. (2013)
- Petrella v. Metro-Goldwyn-Mayer, Inc. (2014)
- American Broadcasting Cos., Inc. v. Aereo, Inc. (2014)
- Star Athletica, LLC v. Varsity Brands, Inc. (2017)
- Fourth Estate Public Benefit Corp. v. Wall-Street.com (2019)
- Rimini Street Inc. v. Oracle USA Inc. (2019)
- Allen v. Cooper (2020)
- Georgia v. Public.Resource.Org, Inc. (2020)
|
---|
Other copyright cases | |
---|
Other patent cases | - Continental Paper Bag Co. v. Eastern Paper Bag Co. (1908)
- Minerals Separation, Ltd. v. Hyde (1916)
- United States v. General Electric Co. (1926)
- United States v. Univis Lens Co. (1942)
- Altvater v. Freeman (1943)
- Sinclair & Carroll Co. v. Interchemical Corp. (1945)
- Funk Bros. Seed Co. v. Kalo Inoculant Co. (1948)
- Great Atlantic & Pacific Tea Co. v. Supermarket Equipment Corp. (1950)
- Graver Tank & Manufacturing Co. v. Linde Air Products Co. (1950)
- Aro Manufacturing Co. v. Convertible Top Replacement Co. (1961)
- Compco Corp. v. Day-Brite Lighting, Inc. (1964)
- Wilbur-Ellis Co. v. Kuther (1964)
- Brulotte v. Thys Co. (1964)
- Walker Process Equipment, Inc. v. Food Machinery & Chemical Corp. (1965)
- Graham v. John Deere Co. (1966)
- United States v. Adams (1966)
- Brenner v. Manson (1966)
- Lear, Inc. v. Adkins (1969)
- Anderson's-Black Rock, Inc. v. Pavement Salvage Co. (1969)
- Zenith Radio Corp. v. Hazeltine Research, Inc. (1971)
- Gottschalk v. Benson (1972)
- United States v. Glaxo Group Ltd. (1973)
- Dann v. Johnston (1976)
- Sakraida v. Ag Pro Inc. (1976)
- Parker v. Flook (1978)
- Diamond v. Chakrabarty (1980)
- Diamond v. Diehr (1981)
- Bonito Boats, Inc. v. Thunder Craft Boats, Inc. (1989)
- Eli Lilly & Co. v. Medtronic, Inc. (1990)
- Markman v. Westview Instruments, Inc. (1996)
- Warner-Jenkinson Co. v. Hilton Davis Chemical Co. (1997)
- Pfaff v. Wells Electronics, Inc. (1998)
- Dickinson v. Zurko (1999)
- Florida Prepaid Postsecondary Education Expense Board v. College Savings Bank (1999)
- J. E. M. Ag Supply, Inc. v. Pioneer Hi-Bred International, Inc. (2001)
- Festo Corp. v. Shoketsu Kinzoku Kogyo Kabushiki Co. (2002)
- Merck KGaA v. Integra Lifesciences I, Ltd. (2005)
- eBay Inc. v. MercExchange, L.L.C. (2006)
- Illinois Tool Works Inc. v. Independent Ink, Inc. (2006)
- LabCorp v. Metabolite, Inc. (2006)
- MedImmune, Inc. v. Genentech, Inc. (2007)
- KSR International Co. v. Teleflex Inc. (2007)
- Microsoft Corp. v. AT&T Corp. (2007)
- Quanta Computer, Inc. v. LG Electronics, Inc. (2008)
- Bilski v. Kappos (2010)
- Global-Tech Appliances, Inc. v. SEB S.A. (2011)
- Stanford University v. Roche Molecular Systems, Inc. (2011)
- Microsoft Corp. v. i4i Ltd. Partnership (2011)
- Mayo Collaborative Services v. Prometheus Laboratories, Inc. (2012)
- Kappos v. Hyatt (2012)
- Bowman v. Monsanto Co. (2013)
- Gunn v. Minton (2013)
- Association for Molecular Pathology v. Myriad Genetics, Inc. (2013)
- FTC v. Actavis, Inc. (2013)
- Alice Corp. v. CLS Bank International (2014)
- Akamai Techs., Inc. v. Limelight Networks, Inc. (2014)
- Teva Pharmaceuticals USA, Inc. v. Sandoz, Inc. (2015)
- Kimble v. Marvel Entertainment, LLC (2015)
- Apple Inc. v. Samsung Electronics Co. (2016)
- TC Heartland LLC v. Kraft Foods Group Brands LLC (2017)
- Peter v. NantKwest, Inc. (2019)
|
---|
Other trademark cases | |
---|
|
|
|
Habeas corpus Suspension Clause of Section IX |
---|
|
|
No Bills of Attainder or Ex post facto Laws Clause of Section IX |
---|
|
|
|
|
Compact Clause of Section X |
---|
|
|