In its recent decision in Hillman v. Maretta, the U.S. Supreme Court considered whether a state law providing for the automatic revocation of a beneficiary designation in the event of divorce was preempted by a federal law providing for the enforcement of a beneficiary designation under a federal life insurance policy. 133 S. Ct. 1943, 1945 (June 3, 2013). Specifically, the Virginia state law at issue provided that a former spouse who recovers "death benefits" in violation of the statute was personally liable to the person to whom the benefits should have been paid. Id. at 1948. In effect, the Virginia law redirected to whom the benefits should be paid without regard to insured's beneficiary designation.