856
Breyer, J., dissenting
Respondents 1, 2. The parties agree that this meant that Isaac received one-third of her estate outright. Under Louisiana law, the three sons of Dorothy and Isaac would receive what was left of the remaining two-thirds at Isaac's death (i. e., the "naked ownership," or the equivalent of a common-law remainder).
Throughout his working life, and during his entire 30-year marriage to Dorothy, Isaac participated in a set of Bell-South's ERISA-qualified retirement plans. When Isaac retired in 1985 (six years after Dorothy's death), he received three assets from those plans: (1) 96 shares of AT&T stock (from BellSouth's Employee Stock Ownership Plan); (2) a cash payment of about $150,000 (from BellSouth's Savings Plan for Salaried Employees); and (3) an annuity of about $1,800 per month (from BellSouth's Management Pension Plan) for his life and afterwards for that of his surviving second spouse, Sandra. Isaac almost immediately placed the $150,000 cash payment in an Individual Retirement Account (IRA), thereby avoiding immediate payment of an income tax. See 26 U. S. C. § 408(e)(1); see also S. Bruce, Pension Claims: Rights and Obligations 7 (2d ed. 1993). Isaac bequeathed a lifetime usufruct in his property, presumably including some or all of the AT&T stock and the funds in the IRA, to his second wife, Sandra. Sandra, as his survivor, also began to receive the $1,800 monthly annuity.
B
On December 17, 1992, Sandra Boggs filed an action for declaratory judgment in Federal District Court. See 29 U. S. C. § 1132(a)(1)(B) (plan participant or beneficiary may bring action to "clarify . . . rights to future benefits"). She said that the three children of Isaac and Dorothy had themselves brought an action in state court against her and against Isaac's estate, seeking a portion of the pension benefits from the BellSouth plans. The children said that under Louisiana law, their mother, Dorothy, had owned a one-half
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