"Despite [waiving any benefits from the Plans, [his ex-spouse] never named a new beneficiary for either Plan. Accordingly, the administrator of the Plans determined that the proceeds of both Plans should be paid to Andochick, because Andochick remained the named beneficiary of the Plans.... Andochick argued that ERISA preempts the waivers embodied in the marital settlement agreement. The Fourth Circuit disagreed, finding that '[a]llowing post-distribution suits to enforce state-law waivers does nothing to interfere' with the core objectives of ERISA. Therefore, the Fourth Circuit determined that Andochick should be paid the benefits from the Plans, but that the decedent's estate could seek to recoup those benefit by enforcing the marital settlement agreement in state court.'"