Clift v. Connecticut General Life Insur. Co., 210 F.3d 268 (5^th Cir. 2000)-This court found that the language in the divorce decree of Pamela and Phillip Clift constituted a valid waiver of Pamela's status as beneficiary of Phillip's life insurance policy, which he held through an employee benefit plan. 

This court declined to set forth a rule that someone cannot effect a waiver in a divorce decree of one's beneficiary interest in a life insurance policy governed by ERISA without specifically listing the "proceeds," "beneficiary interest," or any such "magic words."  The plain language of the divorce decree was clear in its effect:  "[Pamela] is hereby divested of all right, title, interest, and claim in and to ... any and all policies of life insurance (including cash value) insuring the life of [Phillip]."