Beneficiary designation disputes with respect to employee benefits are not uncommon and often present knotty and arcane analytical issues that carry with them the risk of the double payment of benefits and/or litigation. Accordingly, the US Supreme Court’s decision in Kennedy v. Plan Administrators for DuPont Savings and Investment Plan, et al. (January 26, 2009) provided a welcome clarification that, other than as required by a qualified domestic relations order (QDRO), the plan administrator of an employee benefit plan governed by the Employee Retirement Income Security Act of 1974 (ERISA) must look to the documents that govern the plan to determine the beneficiary to whom a deceased participant’s benefits must be paid.