In re Estate of Easterday

*333In these cross-appeals, we consider two issues of first impression. The first issue involves the impact of a pending divorce action on a spouse's entitlement to life insurance benefits, and specifically the interplay between provisions of the Divorce Code, 23 Pa.C.S. §§ 3301 - 3904, the Probate, Estates, and Fiduciaries Code, 20 Pa.C.S. § 101 - 8815 ("PEF Code"), and Rule of Civil Procedure 1920.42(b). The second issue asks whether ERISA1 preempts a state law claim to enforce a contractual waiver to receive pension benefits by the named beneficiary. For the reasons detailed herein, we affirm…