Key Interpleader and Beneficiary Decisions

• 338 U.S. 655
• Decided February 6, 1950
• Opinion by Justice Clark
• National Service Life Insurance

Facts

A soldier insured under the National Service Life Insurance Act named his mother as beneficiary and his father as contingent beneficiary. His widow claimed half of the proceeds under California community-property law, because the premiums had been paid from his army pay.

Holding

The proceeds were payable to the named beneficiary. The state-court judgment awarding the widow a share, and requiring future payments to be turned over to her, could not stand against the federal statute.

Why it matters

An early statement that Congress's choice to let the insured pick a beneficiary under a federal program overrides contrary state property rules. Later decisions in Ridgway and Hillman rely on it.

Opinion: Cornell LII.

• 386 U.S. 523
• Decided April 10, 1967
• Opinion by Justice Fortas
• Interpleader procedure

Facts

In 1964, a Greyhound bus collided with a pickup truck in Shasta County, California. Two passengers were killed and dozens of others were injured. The truck driver's insurer, State Farm, had a policy with limits of $10,000 per person and $20,000 per occurrence. It filed an interpleader in federal court in Oregon, paid the $20,000 into court, and obtained an order requiring all claims arising from the crash, including suits against Greyhound and its driver, to be brought only in that proceeding.

Question

Does the federal interpleader statute require complete diversity among claimants, and can interpleader be used to force all litigation from an accident into one court?

Holding

Section 1335 requires only "minimal" diversity: at least two adverse claimants of different citizenship. That is constitutional, because the complete-diversity rule is a reading of the general diversity statute, not of Article III. But interpleader was "never intended … to be an all-purpose 'bill of peace.'" The injunction had to be narrowed to protect the fund itself, leaving claimants free to sue the other defendants elsewhere.

Why it matters

It is the leading case on the reach and limits of federal statutory interpleader, cited for both the minimal-diversity rule and the principle that a small fund cannot be used to drag unrelated claims into one court.

Opinion: Cornell LII. See also the guide to statutory vs. Rule 22 interpleader.

• 454 U.S. 46
• Decided November 10, 1981
• Opinion by Justice Blackmun
• SGLI

Facts

A Maine divorce decree ordered an Army sergeant to keep his life insurance in force for the benefit of his three children. His coverage was a $20,000 Servicemen's Group Life Insurance policy. He remarried and changed the designation so the proceeds would be paid "by law," which under the federal statute meant his widow. After his death, his first wife sought a constructive trust on the proceeds for the children.

Holding

The insured's designation under the federal program prevailed over the constructive trust imposed by the Maine courts. Under the Supremacy Clause, a state divorce decree must give way to clearly conflicting federal enactments.

Why it matters

Divorce decrees requiring a parent to maintain insurance for children are common. Ridgway shows that for SGLI coverage, such a decree may not be enforceable against the proceeds themselves.

Opinion: Cornell LII. Statute: 38 U.S.C. § 1970.

• 532 U.S. 141
• Decided March 21, 2001
• Opinion by Justice Thomas
• ERISA

Facts

A Boeing employee named his wife as beneficiary of his employer-provided life insurance and pension plan, both governed by ERISA. They divorced in April 1994, and he died about two months later in a car accident without changing either designation. The $46,000 in life insurance proceeds was paid to his former wife. His children from a prior marriage sued under a Washington statute that revokes nonprobate designations of a former spouse upon divorce.

Holding

The Washington statute was preempted as applied to ERISA plans because it had an impermissible "connection with" them: it bound plan administrators to pay according to state law rather than the plan documents, interfering with nationally uniform plan administration.

Why it matters

For employer life insurance and retirement plans governed by ERISA, state revocation-on-divorce statutes generally cannot redirect benefits away from the named beneficiary.

Opinion: Cornell LII.

• 555 U.S. 285
• Decided January 26, 2009
• Opinion by Justice Souter (unanimous)
• ERISA

Facts

William Kennedy named his wife, Liv, as beneficiary of his DuPont savings and investment plan. Their divorce decree divested her of any interest in the plan, but he never filed a new designation. After his death, his daughter, as executrix of his estate, asked the administrator to pay the estate. The administrator paid Liv, the named beneficiary.

Holding

Liv's waiver in the divorce decree was not an "assignment or alienation" barred by ERISA's anti-alienation provision. Even so, the administrator properly paid her, because ERISA requires administrators to act according to the plan documents. The Court declined to decide whether the estate could sue Liv after the money was distributed (555 U.S. at 299 n.10).

Why it matters

It establishes the "plan documents rule" for ERISA plans: the administrator pays whoever the plan documents say, even if a divorce decree says otherwise. The Court expressly left open whether the estate could sue the recipient after payment to enforce the waiver (555 U.S. at 299 n.10). Since then, the Third Circuit (Estate of Kensinger v. URL Pharma, Inc., 674 F.3d 131 (3d Cir. 2012)) and the Fourth Circuit (Andochick v. Byrd, 709 F.3d 296 (4th Cir. 2013)) have allowed such post-distribution suits.

Opinion: Cornell LII.

• 569 U.S. 483
• Decided June 3, 2013
• Opinion by Justice Sotomayor
• FEGLI

Facts

Warren Hillman named his then-wife, Judy Maretta, as beneficiary of his Federal Employees' Group Life Insurance. They divorced, he married Jacqueline Hillman, and he never changed the designation. After his death, Maretta claimed and collected $124,558.03. Jacqueline sued her under a Virginia statute that (in Section D) made a former spouse who receives such benefits liable to whoever would have received them had another provision (Section A) not been preempted.

Holding

Section D was preempted by the Federal Employees' Group Life Insurance Act. Congress intended the proceeds to belong to the named beneficiary, and a state law that lets another person take them away after payment conflicts with that purpose.

Why it matters

For FEGLI, the named beneficiary generally keeps the money even after a divorce, unless a qualifying court decree or order was received by the employing agency (or OPM) before death, as 5 U.S.C. § 8705(e) provides.

Opinion: Cornell LII. Statute: 5 U.S.C. § 8705.

• 584 U.S. 811
• Decided June 11, 2018
• Opinion by Justice Kagan
• State revocation-on-divorce law

Facts

Mark Sveen married Kaye Melin in 1997 and the next year bought a life insurance policy naming her as primary beneficiary and his two children from a prior marriage as contingent beneficiaries. They divorced in 2007; the decree did not mention the policy. After he died in 2011, Melin and the children made competing claims. Minnesota had adopted a revocation-on-divorce statute in 2002, after the policy was bought.

Holding

Applying the 2002 statute to the earlier policy did not violate the Contracts Clause. The law did not substantially impair the contract: it reflects a policyholder's presumed intent, the policyholder could not reasonably have relied on the beneficiary designation surviving a divorce, and the policyholder could undo the result simply by renaming the former spouse.

Why it matters

States may apply revocation-on-divorce statutes to policies purchased before the statute was enacted. The decision does not displace federal preemption under Egelhoff or Hillman for policies governed by federal law.

Opinion: Cornell LII. Statute: Minn. Stat. § 524.2-804.

• 4th Cir.
• 976 F.2d 912
• 1992
• Undue influence

Facts

Dick Leimbach was hospitalized in November 1989 with an inoperable spinal cord tumor and died in January 1990. He had left his wife, Gay, and was living with Marsha Allen. On November 25 he signed a will, prepared with Allen's assistance, saying he intended to change his life insurance beneficiaries to a trust for his daughter. Three days later, he changed the beneficiary of his $129,000 FEGLI policy and $18,000 New York Life policy from Gay to Allen. The trial court found that Allen controlled access to him in the hospital, obtained or helped prepare the forms, arranged the witnesses, and submitted the FEGLI form.

Holding

The Fourth Circuit affirmed the finding of undue influence, concluding that the facts supported each factor Maryland courts use and "convincingly establish[ed]" that Allen's actions destroyed Leimbach's "free agency." The changes failed.

Why it matters

The timing, three days after a will expressing a different plan, was "[p]articularly persuasive." Detailed findings about control and involvement carried the challenge. Contrast Thrivent v. Bressler and Sands v. Midland National, below, where challenges without such evidence failed.

Leimbach v. Allen, 976 F.2d 912 (4th Cir. 1992), No. 91-3054. Caselaw Access Project. See also undue influence and capacity.

• 21 F.3d 380
• 11th Cir.
• No. 92-3111
• Decided May 23, 1994; opinion by Chief Judge Tjoflat (Tjoflat, Dubina and Roney, JJ.)
• Stakeholder's attorney's fees: normal course of business
• Binding only in the Eleventh Circuit

The standard

Courts may deny a stakeholder its fees from the fund "when a stakeholder's interpleader claim arises out of the normal course of business," a standard that "typically is applied to insurance companies." Insurers face competing claims to policy proceeds "with some modicum of regularity," and "[a]s the costs of these occasional interpleader actions are foreseeable, the insurance company easily may allocate the costs of these suits to its customers." Unlike a stakeholder that comes into a disputed asset unexpectedly, an insurer "can plan for interpleader as a regular cost of business and, therefore, is undeserving of a fee award" (at 383).

Background

The opinion arose from a bank's request for fees in a bankruptcy interpleader over a disputed deposit. The lower courts had ruled that banks can never be paid for an interpleader. The Eleventh Circuit called that rule "overly broad," noting that a bank "acting merely as a depository" may be entitled to fees, and sent the request back for reconsideration without deciding whether any fees were owed (at 383–84).

Not an absolute bar

The court noted that even insurers have been awarded fees for disputes "which do not ordinarily rise in the course of the insurance business" (at 383 n.2). District courts in the circuit have awarded insurers fees for work beyond the routine, as in Primerica v. Donley.

Why it matters

The decision is binding only in the Eleventh Circuit, which covers the federal courts in Alabama, Florida and Georgia. There, it is the decision courts cite when they refuse or reduce an insurer's request to pay its lawyers out of a death benefit. The Seventh Circuit, which covers Illinois, Indiana and Wisconsin, treats the same idea as a condition for fees rather than an exception to them: in Aaron v. Mahl, 550 F.3d 659, 667 (7th Cir. 2008), it described fees as available to a prevailing stakeholder when they are reasonable and the stakeholder's efforts are not part of its normal course of business, and it upheld an award to a brokerage firm in a complex case with extensive discovery (opinion). Elsewhere, approaches to insurer fee requests vary; see the circuit-by-circuit comparison.

Opinion: Caselaw Access Project, Harvard Law School. See also attorney's fees in interpleader and interpleader as a cost of doing business.

• 6th Cir.
• 227 F.3d 700
• 2000
• Undue influence; ERISA

Facts

Edward Williams had named his niece, Willie Lee Tinsley, as beneficiary of his General Motors life insurance. Several days before his death in December 1996, he signed a new form naming his neighbor, Beulah Calloway, who had cared for him. GM and its insurer deposited $14,077.80 with the court and were dismissed. The district court granted summary judgment for Calloway, finding no competent evidence of undue influence.

Holding

The Sixth Circuit reversed. Applying federal common law, it found that affidavits indicating Calloway "exerted some control over Williams's finances" and neglected him, together with his poor health and the timing, raised a genuine factual question for trial. It also sent back an unaddressed forgery claim.

Why it matters

The challenger did not win the money on appeal, but won the right to a trial. At summary judgment, the question is whether there is enough evidence to require a trial, not who is more believable.

Tinsley v. General Motors Corp., 227 F.3d 700 (6th Cir. 2000), No. 99-2045. Caselaw Access Project. See also undue influence and capacity.

• 688 F.3d 1004
• 9th Cir.
• No. 11-55026
• Filed July 31, 2012; opinion by Judge Paez (Wardlaw, Paez and Rawlinson, JJ.)
• Appeal from C.D. Cal. No. 2:09-cv-06789
• Stakeholder liability
• Reversed and remanded

Facts

The insurer issued an $800,000 life insurance policy. In 2005, family members signed ownership and beneficiary change forms at the insurer's San Francisco office with the help of its director of policy administration, who, according to the opinion, had the insured's grandson sign as an existing owner when he was not one and did not have an actual owner sign a needed form. The insurer recorded the change anyway, and the grandson paid the premiums for about four years. After the insured died in 2009, the insurer told the grandson and another claimant that the 2005 changes had been improperly executed. Other relatives sued the insurer in Los Angeles Superior Court; the insurer removed the case, counterclaimed in interpleader, and deposited the $800,000 plus interest. The grandson's group counterclaimed for negligence. The claimants then settled the fund among themselves, with $290,000 going to the other side, and the district court ruled that the grandson's group had no damages it could recover from the insurer.

Holding

The Ninth Circuit reversed. It held that interpleader does not "shield a negligent stakeholder from tort liability for its creation of a conflict over entitlement to the interpleaded funds," and that "a claimant may seek to recover all damages directly and proximately caused by the negligent stakeholder's conduct" (at 1006). Here, those claimed damages were the $290,000 the group gave up in the settlement and the attorney's fees it spent litigating against the other claimants. Because the harm was said to flow from the insurer's negligence rather than from filing the interpleader, the claimants were "not required to show that West Coast acted in bad faith in creating the controversy" (at 1013). The court distinguished Prudential v. Hovis (3d Cir. 2009): a stakeholder that is blameless for the dispute is protected, "but ... a stakeholder whose alleged tort caused the controversy is not absolved of liability by filing an interpleader action" (at 1014). It did not decide whether the insurer was in fact negligent.

Why it matters

Filing an interpleader does not wipe the slate clean for an insurer whose own mistake created the dispute. In the Ninth Circuit, which covers Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon and Washington, a claimant harmed by that kind of mistake may pursue the insurer separately, and the insurer's exposure is not capped at the amount it deposited. The court warned that the opposite rule would turn interpleader into "a species of get-out-of-jail-free card" (at 1013). The claim must be about the insurer's own conduct, not simply its refusal to choose between claimants.

Opinion: Ninth Circuit site (PDF) (also on the Caselaw Access Project). See also when a claimant sues first and what the discharge covers.

• 7th Cir.
• No. 12-1840
• July 31, 2013
• Illinois law

Facts

The insured's wife was the named beneficiary of a life insurance policy. About fifteen months before he died, he filled out a beneficiary change form naming his adult children from an earlier marriage. The form told policyholders to return it to the insurer, but the court found no evidence he ever did, although he had returned change forms for his other insurance and retirement policies. The insurer filed an interpleader.

Holding

Applying Illinois law, the Seventh Circuit held that he neither complied with the policy nor substantially complied, because he never made a "concrete attempt" to carry out the change "as far as was reasonably in his power." It affirmed the judgment for his wife.

Why it matters

A completed form that never reaches the insurer usually will not change the beneficiary when the insured had the time and ability to send it.

Opinion: govinfo.gov (PDF). See also Illinois.

• M.D. Fla. No. 8:20-cv-1581-WFJ-CPT
• Order Dec. 16, 2021
• Aff'd, 11th Cir. No. 22-10220 (Sept. 6, 2023) (unpublished)
• Florida law
• Change not effective

Facts

In 2008 the insured changed the beneficiary of his life insurance policy, which had a face amount of $1,000,000, to his daughter, then a child, as sole primary beneficiary. In November 2009, after remarrying, he submitted a new request naming his wife as 75% primary beneficiary and his daughter as 25% primary beneficiary, along with contingent beneficiaries. The insurer did not record the change. About a week later it sent him a letter saying it could not complete the request until two problems were fixed: the same person was listed as both a primary and a contingent beneficiary, and the relationship of a new contingent beneficiary was not given. The letter enclosed a blank form and instructions. He never responded, and he died in April 2020. His widow and his daughter, a minor acting through her mother, both claimed the proceeds. The insurer filed an interpleader in July 2020. The court denied its first motion to deposit the money and granted a renewed motion in March 2021, and the death benefit went into the court's registry.

Holding

Under Florida law, an insured must strictly comply with the policy's terms to change a beneficiary. The policy allowed a change by written notice "subject to any payment we make or other action we take before recording," which the courts read as permitting objectively reasonable action. Rejecting a defective request, explaining the defects, and supplying a new form was objectively reasonable. The district court said the widow's reading, under which the insurer would essentially have to accept and record every written change form, set "an unrealistic standard," and held that the insured's "failure over a period of nearly eleven years to confirm the acceptance of his 2009 change of beneficiary form prevents any reasonable reliance on that form." It also applied Florida's presumption that a letter mailed in the ordinary course of business was received, after the widow argued he never got the letter. The daughter remained the sole beneficiary, and judgment was entered for her on December 17, 2021. The Eleventh Circuit affirmed: "Because the decedent neither responded to the notice nor inquired as to the status of his filing in the ten years that followed, we conclude that the decedent did not strictly comply with the terms of the policy." It added that "[n]either [the widow] nor anyone else is entitled—after the owner's death—to change the beneficiary."

What happened next

The appeal took about 20 months. It was dismissed for failure to prosecute in March 2022 and reinstated 11 days later; after oral argument the court referred the case to mediation in June 2023, and it decided the appeal on September 6, 2023, taxing costs against the appellant. On September 28, 2023, the district court ordered $1,079,123.29 in the registry, plus all accrued interest, paid to the daughter, discharged the insurer and barred the claimants from suing it over the policy, and ordered each party to bear its own attorney's fees and costs.

Why it matters

Sending in a form is not always enough. If the insurer reasonably flags a defect and the insured never fixes it, the earlier designation can stay in force, even years later.

District court order granting summary judgment, ECF No. 62 (Dec. 16, 2021): court order (PDF) (also on the U.S. District Court, M.D. Fla. site (PDF)). Judgment, ECF No. 63 (Dec. 17, 2021): court judgment (PDF). Appellate opinion, ECF No. 52-1 (Sept. 6, 2023): court copy (PDF) (also on GovInfo and the Eleventh Circuit site (PDF)). See also change of beneficiary.

Standard Insurance Co. v. Guy (6th Cir. 2024)

• 115 F.4th 518
• No. 21-5562 (24a0185p.06)
• Decided Aug. 19, 2024; opinion by Judge Larsen (Griffin, Bush and Larsen, JJ.)
• Appeal from E.D. Tenn. No. 2:18-cv-00074
• ERISA; slayer rule
• Affirmed

Facts

A mother insured herself, and her husband as a dependent, under employer group life and accidental death plans governed by ERISA, and named their son and her husband as beneficiaries. In November 2016 the son killed both parents. A Tennessee jury convicted him of first-degree premeditated murder, and it became final when the Tennessee Supreme Court denied review in November 2023. The insurer filed an interpleader in 2018 against the son, the father's two daughters from an earlier relationship, and the mother's two siblings. If the son was disqualified, the mother's benefits would go to her siblings, and his share of the father's dependent benefits to the father's daughters.

District court

The court stayed the case pending the criminal case and, after the conviction, refused to reinstate the stay while the son appealed: "nothing in Tennessee's slayer statute indicates that a judgment of conviction must be final to be conclusive evidence in a civil matter concerning the proper disposition of life insurance benefits" (ECF No. 70, at 2). On summary judgment it held the son disqualified under Tenn. Code Ann. § 31-1-106, under which a judgment of conviction "is conclusive evidence that the individual is the decedent's killer," or alternatively under federal common law, without deciding whether ERISA preempts the Tennessee statute (ECF No. 120, at 4–6).

Holding

Affirmed. The son argued that ERISA requires the administrator to pay the designated beneficiary. The court held that the pay-the-designated-beneficiary rule from Kennedy "is not absolute," and that "[t]he slayer scenario is more like the doctrines of undue influence and fraud addressed in Tinsley than the divorce and waiver at issue in Kennedy" (slip op. at 9). Because ERISA is silent, federal common law supplies the rule, and the slayer rule's long history meant that, "[a]ssuming that ERISA preempts Tennessee's slayer statute, the federal common-law slayer rule controls in this case" (at 10–12). The court "need not definitively resolve the preemption issue left open in Egelhoff," because the son lost under either source of law (at 5). It noted possible exceptions for self-defense or accident, none of which applied (at 12).

Outcome

Under the district court's judgment, $584,478.84 went in equal shares to the mother's two siblings and $117,597.85 in equal shares to the father's two daughters, each with prorated interest (ECF No. 121).

Why it matters

In the Sixth Circuit, a beneficiary who murders an ERISA plan participant cannot collect even if a state slayer statute were preempted. The Seventh Circuit has held that ERISA does not preempt state slayer statutes; the Sixth Circuit left that question open (at 5). The insurer's role ended early: it was discharged in February 2020 with a reduced fee award, long before the claimants' dispute was resolved.

Court copies: Sixth Circuit opinion and judgment, Aug. 19, 2024 (PDF), also on the Sixth Circuit's website (PDF); order denying reinstatement of the stay, Dec. 1, 2020, ECF No. 70 (PDF); memorandum opinion and order, May 20, 2021, ECF No. 120 (PDF); judgment, ECF No. 121 (PDF). See also the slayer rule and ERISA and slayer statutes.

Metropolitan Life Ins. Co. v. Vasquez (5th Cir. 2025)

• No. 24-11024, 2025 WL 2795055
• Decided Oct. 1, 2025 (per curiam; Elrod, C.J., Clement and Haynes, JJ.)
• Unpublished
• Appeal from N.D. Tex. No. 4:24-cv-00009-BJ
• FEGLI
• Reversed and remanded; later settled

Facts

A Defense Department aircraft technician named his mother as beneficiary of his Federal Employees' Group Life Insurance in 2007. After he married, and before deploying to Afghanistan, he signed a 2013 form naming his wife, witnessed by two people. His supervisor declared that he watched the employee copy the form and hand it to the Human Resources officer on duty at his facility. After the employee died in September 2021, the Defense Department told the program's administrator that the only form in his personnel file was the 2007 form, and it could not locate the 2013 form. The administrator found the mother's claim valid and denied the widow's claims. After the widow sued it directly, it filed an interpleader on January 4, 2024. The district court discharged the insurer on deposit in March 2024.

District court

On cross-motions for summary judgment, the court held that a form not in the personnel file "must then bear some indicia of the receipt," and that "without any indicia of receipt by the appropriate office, mere delivery alone is insufficient" (ECF No. 32, at 13, 17). It entered judgment for the mother.

Holding

Reversed. Under 5 U.S.C. § 8705(a), payment goes first to the beneficiary "designated by the employee in a signed and witnessed writing received before death in the employing office" (slip op. at 4). Following Coomer v. United States, 471 F.2d 1, 5 (5th Cir. 1973), a servicemembers' insurance case, the court held that "received" "does not require that the beneficiary designation form bear some indicia of receipt or be present in an insured's personnel file," and that a form is "received" "when an insured individual hands the form to an appropriate person at the insured's employing office" (at 6). "Evidence of receipt may take various forms, including witness testimony" (at 7), and challenges to the supervisor's "decade-old testimony" were credibility attacks not suited to summary judgment (at 7–8). The evidence created a genuine dispute for trial but did not entitle the widow to judgment (at 8). Whether the official on duty at that facility was the "employing office" was left to the district court (at 8 n.4).

Afterward

The First Circuit called the holding "instructive" in Hebert v. Donahue, No. 24-1951 (1st Cir. Feb. 5, 2026), slip op. at 23. In Vasquez itself the claimants settled after remand, and on January 26, 2026, the district court entered a final judgment dismissing all claims with prejudice.

Why it matters

A lost or unrecorded federal beneficiary form is not necessarily ineffective. A claimant who can prove delivery, including through a witness, can get to trial even when the agency has no copy. Delay is a risk in these cases: about two years and four months passed between the death and the interpleader, in part because of the widow's earlier direct suit against the insurer, and about 11 months between the district court's judgment and the appellate opinion.

Court copies: Fifth Circuit opinion, Oct. 1, 2025, as filed in the district court (PDF); Fifth Circuit judgment (PDF); district court memorandum opinion, Oct. 22, 2024, ECF No. 32 (PDF); deposit and discharge order, Mar. 6, 2024, ECF No. 14; final judgment, Jan. 26, 2026, ECF No. 46 (PDF). See also federal programs and change of beneficiary.

• N.Y. Court of Appeals
• 92 N.Y.2d 436
• November 20, 1998
• Change of beneficiary

Facts

The insured named his wife as beneficiary of a group life insurance policy that let him change the beneficiary "by written request filed" with his employer or the insurer. They divorced in 1978. Their settlement agreement, incorporated into the divorce decree, released her rights in his property and estate but did not mention the policy. A handwritten will he wrote in 1977 left his "insurance benefits" to his father. He died in 1984 without changing the designation. The former wife sued the insurer for the proceeds, about $16,000. The insurer interpleaded the father, as administrator of the estate, paid the money into court and was discharged.

Holding

The will did not change the beneficiary. The court did not decide whether Delaware or Pennsylvania law governed, because the result was the same, and it described the general rule as the same under New York law. As a general rule, the method the policy prescribes must be followed. Strict compliance is not always required, but there must be "some affirmative act or acts" by the insured to make the change; if the insured made "every reasonable effort" to comply, substantial compliance will do. General statements in a will are not substantial compliance, and there was no evidence that he had tried to change the designation in the seven years before his death or was incapable of doing so. An insurer that pays the proceeds into court and asks the court to decide between claimants may no longer insist on strict compliance, but substantial compliance is still required. The court reinstated the judgment for the former wife.

Why it matters

A will generally does not override a beneficiary designation. The insured has to act under the policy's own procedure, or come close by making every reasonable effort to follow it.

Opinion: Cornell Legal Information Institute (unofficial copy of the slip opinion).

• Supreme Court of Alabama
• No. 1170879
• October 26, 2018
• 275 So. 3d 519

Facts

In late 2011 the insured applied for an individual life insurance policy, listing his Alabama home address, and named his daughter as sole beneficiary. After he married in 2012, he made his wife and his daughter 50% beneficiaries each. The couple divorced in February 2016. The divorce judgment did not address the policy, and he never changed the designation before he died later in 2016. His daughter sued, claiming the full proceeds.

Holding

The Alabama Supreme Court affirmed that the daughter was the sole beneficiary because the former wife's designation was revoked under Ala. Code § 30-4-17 by the divorce. It held that Alabama law, not Tennessee law, governed. Applying the statute did not violate the Alabama Constitution's ban on laws impairing contracts: when it took effect in 2015, the statute "did not retroactively impair any existing contractual obligations" but "created a prospective default rule, i.e., that a divorce effectively revokes any revocable beneficiary designation in favor of the former spouse, absent further action by the policyholder." The court also upheld the trial court's finding that the couple had not entered a common-law remarriage.

Why it matters

In Alabama the statute can apply to a policy bought before September 1, 2015, if the divorce came after that date. A later federal court read this "prospective" rule as leaving designations untouched where the divorce came before the statute (Modern Woodmen v. Harris).

Blalock v. Sutphin, 275 So. 3d 519 (Ala. 2018), No. 1170879 (Oct. 26, 2018). FindLaw (unofficial copy).

• Mo. Ct. App., Southern District
• No. SD29793
• June 4, 2010
• Missouri law

Facts

The insured signed a request changing her beneficiaries to a niece and a sister-in-law. The insurer returned it because her signature had to be witnessed by a disinterested party, enclosing a form and a return envelope, and it had no record of receiving the form back. Her sister, the contingent beneficiary on record, and the niece both claimed the proceeds, and the insurer interpleaded.

Holding

Missouri applies substantial compliance, but the insured's intent must be "established beyond question" and the insured must have "done everything possible under the circumstances." The insurer's waiver of its own requirements by interpleading "did not confer rights between" the claimants. The court affirmed the judgment for the sister.

Why it matters

A signed form that the insurer properly rejects, and that the insured had time to fix, usually leaves the earlier designation in place.

Opinion: Justia (unofficial copy). An official court copy could not be located. See also Missouri.

• S.D. Tex.
• 845 F. Supp. 2d 791
• January 13, 2012
• ERISA; post-distribution claim

Facts

The insured obtained two life insurance policies through his employer's voluntary program and named his wife as primary beneficiary of both, with no contingent beneficiary. The couple divorced in Texas in 2009. The divorce decree divested her of all rights in benefits "existing by reason of the husband's past, present, or future employment." He died about six months later without changing either designation. She sued the insurers and the executor of his estate, and the executor and another claimant sued her in state court for breach of contract. That case was removed and consolidated. The insurers deposited the proceeds into the court registry and were dismissed. The former wife and the estate's side filed cross-motions for summary judgment, decided by a magistrate judge with the parties' consent.

Holding

The court held that both policies were part of an ERISA plan, because the employer's role went beyond publicizing the program and collecting and remitting premiums. Applying Kennedy, it held that the plan documents control, and since the insured never submitted a written change, the former wife was the beneficiary and the proceeds "should thus be disbursed to Plaintiff." It then held that the estate's breach of contract claim, which was based on the divorce decree and not on the ERISA plans, was not preempted once the proceeds were distributed under the plan documents, noting that Kennedy had left that question open. Rather than send the claim back to state court, it decided it in the same case and granted summary judgment to the executor and the other claimant on breach of the divorce decree. It denied their request for attorney's fees, because their evidence did not prove presentment of the claim as Texas law requires.

Why it matters

It shows a court deciding both who an ERISA plan must pay and whether that person can keep the money in a single interpleader, before the funds left the registry. It is a trial-court decision and does not bind other courts. See ERISA post-distribution claims.

Flesner v. Flesner, 845 F. Supp. 2d 791 (S.D. Tex. 2012) (Johnson, M.J.). Opinion: HallApproved (unofficial copy, from CourtListener data).

• S.D.N.Y.
• 145 F. Supp. 3d 278
• November 10, 2015
• ERISA; post-distribution constructive trust

Facts

In their 2012 divorce settlement, the insured agreed to keep life insurance paying a total of $4 million to his former wife and their two daughters. He did not. He later obtained a $500,000 policy through a new employer, and the records conflicted over whether the former wife or another woman was the beneficiary. With the consent of all parties, the insurer paid the proceeds into the court registry and the claims against it were dismissed. The court held a bench trial on September 30, 2015.

Holding

The court did not decide who the named beneficiary was. Even assuming the other woman was named, it held under New York law that the insured's obligation under the settlement was enforceable in equity, and it imposed a constructive trust on the proceeds in favor of the former wife and daughters. It held that ERISA "does not preempt the imposition of a constructive trust on the proceeds of the policy," because the insurer had already paid by depositing the money with the court, had no role in what followed and faced no risk of double liability. It ordered the clerk to release the $495,000 held in the registry to the former wife and daughters.

Why it matters

The court treated the insurer's deposit into the registry as the distribution, so a state-law claim against the beneficiary could be decided in the same case before any money reached her. See ERISA post-distribution claims.

McCarthy v. Estate of McCarthy, 145 F. Supp. 3d 278 (S.D.N.Y. 2015) (Furman, J.). Opinion: Caselaw Access Project.

• D. Ariz.
• No. CV-16-08135-PCT-BSB
• March 16, 2017
• Capacity and undue influence

Facts

At her death the decedent owned three contracts issued by the insurer: a life insurance contract, a deferred annuity and a settlement agreement. Each let her change the beneficiary. In October 2013 she signed a form naming one daughter as sole primary beneficiary of all three, with a second daughter as contingent beneficiary, and the insurer approved the designation in November 2013. After her death the second daughter and the decedent's son disputed the primary beneficiary's claim, and the insurer filed an interpleader under Rule 22. In December 2016 it deposited the proceeds of the three contracts, with accrued interest, in the total amount of $277,101.97. In January 2017 the court found that the insurer was a disinterested stakeholder that had interpleaded in good faith, awarded its attorneys' fees and costs from the fund, and dismissed and discharged it. The named beneficiary then moved for summary judgment. The second daughter admitted that the form named her sister, but argued that medication and medical treatment had affected their mother's judgment and memory, that she had been confused or mistaken, and that a family friend or the insurance agent had unduly influenced her. She cited no legal authority and argued that the three children should share the proceeds equally. The son, who had made similar assertions in his answer, did not respond to the motion.

Holding

Applying Arizona law, the court granted summary judgment for the named beneficiary. On capacity, it said Arizona law presumes that a person has the mental capacity to exercise contractual rights, including the right to change a beneficiary. The challenger conceded that her mother had not been found incompetent, and there was no evidence that she was. On confusion or mistake, the court said that under Arizona law the insured's intent governs competing claims to insurance proceeds. The undisputed evidence showed the decedent's intent, including a long-time friend's declaration that the decedent had told her of the choice, while the challenger offered no details or evidence of confusion. On undue influence, the challenger offered no evidence. She stated only that she had "a belief that there was undue influence" and said she was not claiming the form was signed under duress. Conclusory allegations and unsupported speculation were not enough to create a genuine dispute. The same day, judgment was entered for the named beneficiary in the amount of $267,955.72, "the amount arrived at after reduction by an award of attorneys' fees and costs on January 30, 2017 in the amount of $9,146.25."

Why it matters

Serious illness, treatment side effects and a relative's belief that something was wrong do not by themselves overturn a signed designation. A challenger needs specific evidence about the insured's condition at signing or about what the alleged influencer actually did. Sands v. Midland National, below, reached the same result under California law.

Thrivent Financial for Lutherans v. Bressler, No. CV-16-08135-PCT-BSB (D. Ariz.): order granting motion for partial summary judgment (signed Mar. 15, filed Mar. 16, 2017, ECF No. 67), court order (PDF); judgment in a civil case (Mar. 16, 2017) (PDF), a copy of the court's filed judgment. See also undue influence and capacity.

• M.D. La.
• No. 3:16-cv-00247-RLB
• Mar. 23, 2017
• Partial summary judgment; Louisiana law

Facts

The owner of a variable deferred annuity issued in 1994 named his daughter as beneficiary. In August 2015 he signed a durable power of attorney naming a relative as his agent. The agent gave the insurer a copy of the power of attorney and sent a change form naming herself sole beneficiary. The owner died in December 2015, leaving all of his property by will to a sole legatee. Days later the insurer told the agent it was "unable to accept the beneficiary designation as indicated on the request" because the power of attorney did not allow her to change beneficiaries. A state court then issued a judgment of possession directing insurers holding property of the succession to deliver it to the legatee. The legatee, the daughter and the agent each demanded the proceeds, and the insurer filed a statutory interpleader on April 19, 2016 and deposited the funds on May 3, 2016. The parties consented to decision by a magistrate judge. The agent and the legatee also counterclaimed against the insurer; that counterclaim was not part of this ruling.

Holding

The legatee: La. R.S. 22:912(B)(1) makes the lawful beneficiary of an annuity contract "entitled to the proceeds and avails of the contract against the creditors and representatives of the annuitant . . . and against the heirs and legatees of either person, saving the rights of forced heirs." A claim based on being "the sole legatee" of the owner's estate was therefore "invalid" (at 5). The agent: Civil Code article 2998 provides that "[a] mandatary who represents the principal as the other contracting party may not contract with himself unless he is authorized by the principal, or, in making such contract, he is merely fulfilling a duty to the principal," and "courts have concluded that a power of attorney must expressly grant the right to a designated agent to self-deal by naming oneself a beneficiary to an annuity contract" (at 6). Paragraph 7 of this power let the agent "make any elections and disclaimers under such policies," but paragraph 15 barred her, "unless specifically authorized by this document," from designating the owner's assets or rights to herself. "Read in conjunction, Paragraph 15 limits the grant of power in Paragraph 7" (at 7). A clause the claimants relied on "merely provides that specific grants of powers are illustrative, not exhaustive," and no specific authorization existed (at 8). Fees: the insurer and the daughter had agreed on $8,250 in fees and costs, but the court asked for more support: "[a]t a minimum, an affidavit by the attorneys with an explanation of the work performed, including a representation regarding the general time billed and reasonable rates charged, is appropriate" (at 9).

Outcome

A consent judgment on May 24, 2017 recognized the daughter as the proper beneficiary and awarded her $111,308.15 plus all accrued interest on the funds deposited, "less any assessed fee for administration of the funds," and awarded the insurer $8,250.00 (ECF No. 30). The court ordered the registry funds disbursed on June 13, 2017 (ECF No. 31).

Why it matters

Broad authority to "make any elections" under a policy did not include naming the agent herself, where the same document limited self-dealing. In Louisiana, annuity proceeds payable to a named beneficiary also pass outside the will. The ruling also shows a court asking for proof behind even an agreed stakeholder fee. See change of beneficiary and Louisiana.

Transamerica Advisors Life Ins. Co. v. Marsch, No. 3:16-cv-00247-RLB (M.D. La.) (Bourgeois, M.J., by consent): consent ruling on motion for partial summary judgment (signed Mar. 22, 2017, filed Mar. 23, 2017, ECF No. 28), court order (PDF); consent judgment (May 24, 2017, ECF No. 30), court judgment (PDF); consent order disbursing registry funds (June 13, 2017, ECF No. 31). Statute: La. R.S. 22:912 (Louisiana State Legislature).

• D. Colo.
• No. 1:16-cv-01136-RM-KLM
• Recommendation Feb. 27, 2017; adopted Mar. 29, 2017
• Summary judgment; Colorado law

Facts

An insured named his wife as primary beneficiary of a life policy issued in 2002 and his son as successor beneficiary. The divorce decree was entered on July 6, 2015, with property issues reserved, and the insured died eight days later. In November 2015 the divorce court entered permanent orders, nunc pro tunc to July 6, 2015, that recited a cash surrender value of $40,000 and awarded the former wife "fifty-percent of the value of [the insured's] life insurance policy." The insurer interpleaded the death benefit, about $69,605, and the former wife and the son both claimed it.

Holding

Colorado's revocation-on-divorce statute yields to "the express terms of a governing instrument, a court order, or a contract relating to the division of the marital estate," and the permanent orders were such a court order. Because "[n]unc pro tunc judgments operate retrospectively," the award was measured on July 6, 2015, before the death: "There is no dispute that the 'value' of the policy on the effective date of the Permanent Orders was its cash surrender value, or $40,000." The former wife took half of that, $20,000, and the son, as successor beneficiary, took the remaining $49,605, each with proportionate interest. The court also noted that nunc pro tunc orders "may not be collaterally attacked in a different court proceeding."

Outcome

The district judge adopted the recommendation. The disbursement order paid each claimant the awarded amount plus a proportionate share of the registry interest, and the case closed in April 2017, about 11 months after it was filed.

Why it matters

A divorce order can keep a former spouse in the picture despite a revocation statute, but only to the extent of what the order actually awards. An award of the policy's "value" fixed at a date before death is not the same as an award of the death benefit.

State Farm Life Ins. Co. v. Hoops, No. 1:16-cv-01136-RM-KLM (D. Colo.): recommendation (PDF), order adopting it (PDF), disbursement order, order dismissing the insurer. See also divorce.

• D. Nev.
• No. 2:17-cv-01555-JCM-NJK
• July 3, 2018
• Default judgment; choice of law

Facts

The insurer issued two life insurance contracts to the insured in 1985 and 1989, while she was married, and her husband was the primary beneficiary on both. The couple divorced in California in 2014, and the divorce decree did not mention the contracts. Well after the divorce she moved to Nevada. After her death the executor of her will contested the insurer's payment to the former husband, and the insurer filed an interpleader under the federal interpleader statute against both of them. According to the former husband, the executor had taken the position before the lawsuit that Nevada's revocation-on-divorce statute applied because she had moved to Nevada shortly before her death. The executor was served but never appeared, and through his lawyer told the insurer's counsel he did not intend to. The clerk entered his default, and the former husband moved for default judgment. On the court's order, the insurer deposited the proceeds, with accrued interest, and moved to be discharged.

Holding

The court noted that a claimant in an interpleader, not only the plaintiff, may obtain a default judgment against a co-claimant who has defaulted. It then weighed the seven factors the Ninth Circuit set out in Eitel v. McCool, one of which is the merits of the claim. On the merits, the court explained that Nevada's statute, NRS 111.781, revokes a former spouse's designation on, among other things, life insurance, while California's revocation statute does not reach life insurance. It held that California law applied: the couple divorced in California, the decree was entered under California law, the decree stated that each party was aware of California Family Code § 2024, whose required notice says that a divorce "does not automatically cancel your spouse's rights as beneficiary of your life insurance policy," and the insured did not move to Nevada until well after the divorce. No party pointed to any other event that removed the former husband, and the executor, by not appearing, conceded the point. The remaining factors also favored default judgment. The court declared the former husband the lawful beneficiary of the proceeds, discharged the insurer from further liability, permanently enjoined both claimants under 28 U.S.C. § 2361 from bringing claims against it related to the contracts, dismissed it, and directed the former husband to submit a proposed final judgment.

Key passages

"While more frequently it is the plaintiff who moves for entry of default judgment, courts recognize the right of a defendant in an interpleader action to obtain a default judgment" (p. 3). On prejudice, the court accepted the former husband's point that if the case persisted, "more and more contract proceeds go towards paying legal fees," reducing his recovery (p. 4). "The court holds that California law applies to this dispute" (p. 4). The executor's "intentional avoidance of this lawsuit makes adjudication of this case on the merits a practical impossibility" (p. 6). The court discharged the insurer and enjoined further claims under 28 U.S.C. § 2361 (pp. 3, 6).

Why it matters

The state where the couple divorced, and the law the decree was entered under, can control rather than the state where the insured later lived or died. This was a default judgment decided without opposing argument, but the court still had to decide the choice-of-law question as part of the merits before entering judgment. Compare Modern Woodmen v. Harris, below, where a court applied Alabama law rather than the law of the state where the insured died. The opinion's statement that a claimant may take a default judgment was later quoted in Prudential v. Iturbide.

Thrivent Financial for Lutherans v. Bloomquist, No. 2:17-cv-01555-JCM-NJK (D. Nev. July 3, 2018), order granting default judgment and discharge, ECF No. 32, court order (PDF). See also divorce and California.

• S.D. Miss.
• No. 2:17-cv-103-KS-JCG
• Sept. 25, 2018
• Mississippi law

Facts

The insured was killed in his home in 2011. The coroner and the sheriff's department ruled the death a homicide, and no one had been arrested in the nearly seven years before the ruling. His wife was the named beneficiary. His estate claimed she had caused his death, and the insurer filed an interpleader. In opposing summary judgment, the estate relied on an affidavit from a relative describing the marriage and the scene, and on the circumstances of a later death. As the court put it, "While it may be suspiciously coincidental that Emma Raine's second husband was shot and killed, that she was convicted for her role in that murder, and that she collected life insurance money, without more, the Estate has nothing more than mere speculation at this point."

Holding

Under Mississippi's slayer statute, Miss. Code Ann. § 91-1-25, the estate had to prove by a preponderance of the evidence that the beneficiary willfully caused or procured the death. The court found that the affidavit offered no personal knowledge tying her to the death, and that the other points, without more, were "nothing more than mere speculation." It granted summary judgment for the named beneficiary. The estate then moved for reconsideration based on a state chancery court's default judgment, but the chancery court vacated that judgment on October 4, 2018, which made the point moot, and the court found no ground under Rule 59(e) to revisit the affidavit (Oct. 16, 2018). A separate cross-claim by the United States against her share was resolved by agreement, and the court entered a final judgment and order of disbursement on October 18, 2018.

Why it matters

Suspicion, even strong suspicion, is not evidence. A party invoking a slayer statute in a civil case must come forward with specific evidence that the beneficiary caused the death.

Garden State Life Ins. Co. v. Estate of Raine, No. 2:17-cv-103-KS-JCG (S.D. Miss.) (Starrett, J.): memorandum opinion and order granting partial summary judgment (Sept. 25, 2018, ECF No. 56), court order (PDF); order denying reconsideration (Oct. 16, 2018, ECF No. 61); final judgment and order of interpleader disbursement (Oct. 18, 2018, ECF No. 63), court judgment (PDF). Copies of the court's filed orders. See also the slayer rule and Mississippi.

• C.D. Cal.
• No. 8:18-cv-01325-JLS-ADS
• April 24, 2019
• SGLI; default judgment

Facts

A servicemember insured under Servicemembers' Group Life Insurance died on February 19, 2018. His spouse was the primary beneficiary and his mother the secondary beneficiary. The insurer filed an interpleader on July 31, 2018. As the court recited from the complaint, the spouse had been charged in connection with the death, and the insurer asserted that she "may be disqualified" under Hawaii's slayer statute and the federal SGLI regulation, 38 C.F.R. § 9.5(e). A charge is an accusation, not a finding. The court ordered the benefit deposited in October 2018 and in February 2019 discharged the insurer with prejudice, permanently enjoined claims against it, and awarded it a modest fee from the fund "in partial reimbursement" of its costs "as a neutral stakeholder." The spouse was served in September 2018 but did not answer; the mother answered, the clerk entered the spouse's default, and the mother applied for default judgment. This is a ruling on a default, not a decision on the slayer question.

Holding

The court decided the application on the papers. It noted that "courts recognize the right of a defendant in an interpleader action to obtain a default judgment," quoting Thrivent v. Bloomquist (p. 4), and weighed the Ninth Circuit's Eitel factors. The spouse's criminal defense counsel had indicated that she was aware of the case and did not object, and the court found that "although the Court understands that [her] current incarceration might hamper her participation in this action, it nonetheless reasonably infers that her default was not the product of excusable neglect" (p. 8). It held that "upon entry of default judgment against [the spouse], there are no other remaining claimants to the Proceeds," and quoted Nationwide Mut. Fire Ins. Co. v. Eason, 736 F.2d 130, 133 n.4 (4th Cir. 1984): "Clearly, if all but one named interpleader defendant defaulted, the remaining defendant would be entitled to the fund" (p. 9). It entered default judgment against the spouse, and a final judgment on May 10, 2019, directed the fund paid out and dismissed the case.

Why it matters

A beneficiary accused of causing a death can lose the benefit by default without any court deciding whether a slayer rule applies. The court made no finding about the death and did not decide whether the regulation or the Hawaii statute barred the spouse; her failure to answer decided the case. Incarceration did not excuse the default where she knew of the case. Compare Reliance Standard v. Coleman, another default ruling that did not reach the merits.

Prudential Ins. Co. of America v. Iturbide, No. 8:18-cv-01325-JLS-ADS (C.D. Cal.): order for deposit (Oct. 29, 2018, ECF No. 14); order granting discharge and dismissal (Feb. 27, 2019, ECF No. 29), court order (PDF); civil minutes granting default judgment (Apr. 24, 2019, ECF No. 33), court order (PDF; scanned, with a text layer added); final judgment (May 10, 2019, ECF No. 35), court judgment (PDF). See also the slayer rule and federal programs.

• W.D. Wash.
• No. 2:18-cv-01058-RAJ
• August 2, 2019
• Revocation statute; unmarried partners

Facts

The insured had supplemental life insurance under a group universal life policy issued to his employer. In December 2010 he named his daughter, A.R., a minor, and his then partner, whom the designation described as his "domestic partner," as 50% beneficiaries. Their relationship ended in 2011. In 2012 he removed the former partner from the designations for his other employee benefits, but he never changed the designation under this policy. He died in 2016. A.R. received her half. When the former partner claimed the other half, A.R.'s counsel argued that the insured had kept her on the policy by mistake and that Washington's revocation statute, RCW 11.07.010, revoked her designation. The insurer interpleaded and was discharged. A.R. crossclaimed for a declaration that the insured intended to remove the former partner, and the former partner moved for summary judgment. A.R. did not oppose the motion.

Holding

The court held that RCW 11.07.010 did not apply. Its plain text reaches only the dissolution or invalidation of a marriage or a state registered domestic partnership, or the termination of a state registered domestic partnership, and it was undisputed that the insured and the former partner had never married or registered a domestic partnership. Applying Washington law, the court held that the policy should be enforced as written. A.R.'s uncorroborated allegations about the insured's changes to his other benefits, and her speculation about his intent, did not create a genuine factual dispute. It granted summary judgment to the former partner. The judgment awarded her "$69,501.95, plus any accumulated interest held in the Court's registry, minus any statutory users fees."

Why it matters

A revocation-on-divorce statute generally reaches only the legal relationships it names. Ending an informal relationship does not revoke a designation, and evidence about what the insured meant to do, as distinct from what he did under the policy, is not enough on its own. The policy was an employer group policy. The order decided the case under Washington law and did not discuss ERISA or Egelhoff, which held that ERISA preempts this same Washington statute as applied to ERISA plans.

Minnesota Life Ins. Co. v. Roberson, No. 2:18-cv-01058-RAJ (W.D. Wash.): order granting motion for summary judgment (Aug. 2, 2019, ECF No. 31), court order (PDF); judgment in a civil case (Sept. 26, 2019, ECF No. 34), court judgment (PDF). Statute: RCW 11.07.010 (Washington State Legislature). See also divorce.

• N.D. Ind.
• No. 3:18-cv-176-JD-MGG
• Sept. 12, 2019; amended judgment Oct. 23, 2019
• Default judgment; Rule 22 interpleader

Facts

The insured owned a $250,000 life insurance policy naming her husband as primary beneficiary and her four children as contingent beneficiaries. She died on April 23, 2017. The insurer learned that the husband had been charged with her murder and, with the charge pending, could not determine the proper beneficiary. On March 9, 2018 it filed a Rule 22 interpleader, alleging that he might not be entitled to the benefits under Indiana law, including Ind. Code § 29-1-2-12.1, and it deposited $257,982.50 on April 2, 2018. Two of the children were minors and appeared through their guardian. The husband never answered. This is a ruling on a default, not a decision under the slayer statute.

Holding

The husband was served at the county jail under Indiana Trial Rule 4.3, and the clerk entered his default on May 21, 2019; the court noted that he had been convicted of the insured's murder on May 16, 2019. Granting default judgment, the court explained that "[w]hen a named interpleader defendant fails to answer an interpleader complaint and assert a claim to the res, he forfeits any claim of entitlement that he may have asserted," and ordered judgment declaring that he "has defaulted in this interpleader action and has thereby waived any claim he had to the proceeds." It declined to order distribution on that motion, which did not set out a basis for it. The amended judgment of October 23, 2019 provided that each of the four children was entitled to $64,495.62 plus 25% of the accrued interest, discharged the insurer and enjoined further claims against it.

Why it matters

A beneficiary accused of killing the insured can lose by default before any court applies a slayer statute. Even so, the court entered default judgment only after finding that the jailed defendant had been properly served and that he was not a minor, an incompetent person or in military service. Compare Prudential v. Iturbide.

Farmers New World Life Ins. Co. v. Gathright, No. 3:18-cv-176-JD-MGG (N.D. Ind.) (DeGuilio, J.): order granting deposit (Mar. 22, 2018, ECF No. 7); clerk's entry of default (May 21, 2019, ECF No. 50); opinion granting default judgment (Sept. 12, 2019, ECF No. 59), court order (PDF); amended judgment (Oct. 23, 2019, ECF No. 63), court judgment (PDF). See also the slayer rule.

• N.D. Ala.
• No. 3:18-cv-00995-AKK
• Ruling Oct. 18, 2019; final judgment Oct. 30, 2019
• Partial summary judgment; Alabama slayer statute

Facts

The insured's wife was the named primary beneficiary of a spouse rider on a life policy. After the insured was killed in 2017, the insurer interpleaded and deposited the benefit. Minor children who were contingent beneficiaries, represented by a court-appointed guardian ad litem, opposed payment to the primary beneficiary because a police investigation of the death remained open.

Holding

Alabama's slayer statute, Ala. Code § 43-8-253(c), disqualifies a beneficiary who "feloniously and intentionally" killed the insured. The court noted that law enforcement had not arrested or charged the primary beneficiary and that she had not been convicted of any crime related to the death, and that the children offered no evidence tending to show her involvement. "[B]ecause the children rely solely on the existence of an open investigation, and have not presented any credible evidence that [the primary beneficiary] was responsible for the insured's murder, [her] motion ... is GRANTED."

Outcome

The insurer was discharged and awarded $3,750 in fees from the fund. The final judgment paid $1,800 to the guardian ad litem and the remaining $297,717.12, plus all accrued interest, to the primary beneficiary, about 16 months after the case was filed.

Why it matters

The claimant opposing payment must offer evidence. An unresolved investigation, by itself, does not disqualify a named beneficiary.

Primerica Life Ins. Co. v. Donley, No. 3:18-cv-00995-AKK (N.D. Ala.): final judgment (PDF), discharge and fee order (PDF), order appointing guardian ad litem, deposit order. See also the slayer rule.

• W.D. Wash.
• No. 2:19-cv-00364-JLR
• Jan. 28, 2020; judgment May 11, 2020
• Default judgment; ERISA

Facts

An employee insured under his employer's group term life policy, governed by ERISA, had named his mother as beneficiary. He died in November 2018 without a will, and his spouse, appointed administrator of his estate, wrote to the employer and the insurer contesting the mother's entitlement because community funds had paid for the coverage. The insurer interpleaded the $332,000 benefit. The mother answered; the estate waived service but never appeared, and the clerk entered its default.

Holding

The court granted interpleader because the insurer had a "reasonable fear of double liability": the estate's pre-suit letters were enough to establish a "colorable competing claim" even though it never appeared. On default judgment, the court still weighed the merits. The mother's claim rested on her status as the sole named beneficiary, which "[b]oth ERISA and the plan documents support," and "ERISA preempts Washington's community property laws, leaving the Estate without claim to the Proceeds."

Outcome

Default judgment for the named beneficiary. The court ordered the insurer to deposit the benefit with interest after the ruling, then ordered the $332,000 plus accrued interest disbursed to the named beneficiary and entered judgment, about 14 months after the complaint.

Why it matters

This is a default judgment, not a contested ruling. It shows that a surviving spouse's community-property claim to ERISA group life benefits does not defeat the plan's named beneficiary, and that pre-suit demand letters can be enough to justify interpleader.

Sun Life Assurance Co. of Canada v. Estate of Wheeler, No. 2:19-cv-00364-JLR (W.D. Wash.): order granting interpleader and default judgment (PDF), disbursement order, judgment (PDF), clerk's order of default. See also ERISA.

• E.D. Tex.
• No. 1:18-cv-00523-MAC
• May 3, 2020
• Forgery, capacity and undue influence (Texas law)

Facts

The insured had a $100,000 individual life insurance policy. In 2014 he named his son as primary beneficiary and a long-time friend as contingent beneficiary. On May 13, 2018, during a period when he had been hospitalized, he signed a change form naming the friend, by then his fiancée, as primary beneficiary and her son as contingent beneficiary, removing his own son entirely. The insurer acknowledged the change on May 23, 2018. He entered hospice on July 16, 2018, married the fiancée three days later, and died on July 25, 2018. Both the son and the wife claimed the proceeds. The insurer filed an interpleader on October 15, 2018, deposited $100,526.03 in the court's registry, and was dismissed. The court then realigned the parties, making the son the plaintiff because he carried the burden of showing that the most recent designation was invalid. He argued that his father had not made the change, pointing out that the beneficiary section was not in his father's handwriting and that the form called the fiancée's son the insured's son. In the alternative he argued lack of capacity and undue influence, citing her move from another state after the insured fell ill and the wedding three days after hospice began. The wife moved for summary judgment, relying on her affidavit that she watched the insured sign the form, a notarized power of attorney he signed two days later, the notary's certificate, and a video of him answering questions about the power of attorney.

Holding

The court granted summary judgment for the wife, applying Texas contract law. Fraud: the son's statements that his father "did not make" the change and that there was "no way" he would have done so without telling him were too vague to meet the particularity requirement of Federal Rule of Civil Procedure 9(b) (pp. 7–11). Compliance and signature: the policy allowed a change by notice to the insurer and did "not require that the form be wholly in the insured's handwriting to be valid" (p. 12). The notarized power of attorney was "self-authenticating and competent evidence" of the insured's signature, the two signatures appeared "quite similar," and the son offered no witness affidavits or handwriting expert, so there was no genuine dispute that the insured signed the form (pp. 13–14). Capacity: Texas presumes a person signing a contract has capacity. The son was not present at the signing, relied on phone calls and the misidentified contingent beneficiary, and offered no medical records, witness affidavits or other evidence. "Evidence that creates only a suspicion of mental incapacity is not sufficient to support a finding of lack of mental capacity" (pp. 14–16). Undue influence: applying the Texas three-part test (the existence and exertion of an influence, that it subverted or overpowered the insured's mind when the document was signed, and that the document would not have been signed but for it), the court found the son offered nothing "other than potential opportunity and his personal opinion," and his claim was "mere speculation" (pp. 16–18). The final judgment, entered May 6, 2020, ordered that the son "take nothing" and that the wife recover the registry funds "plus any accrued interest." The docket shows no appeal.

Why it matters

A late-life change to a new partner, a hospice wedding and an imperfect form can raise questions, but they do not by themselves create a triable case. The challenger has to produce evidence, such as witnesses, medical records or a handwriting expert, while the named beneficiary here had a witness affidavit, a notarized document signed two days later and a video. Compare Thrivent v. Bressler and Sands v. Midland National, which reached the same result under Arizona and California law.

Harris v. Wiggins (originally Primerica Life Ins. Co. v. Wiggins), No. 1:18-cv-00523-MAC (E.D. Tex.): memorandum and order granting summary judgment (signed May 3, 2020, ECF No. 25), court order (PDF); final judgment (May 6, 2020, ECF No. 27), court judgment (PDF); order disbursing the registry funds and all interest to the named beneficiary (June 8, 2020, ECF No. 29); memorandum and order realigning the parties (Jan. 29, 2019, ECF No. 13). The undue-influence test comes from Rothermel v. Duncan, 369 S.W.2d 917, 922 (Tex. 1963), as quoted in Wackman v. Rubsamen, 602 F.3d 391, 412–13 (5th Cir. 2010). See also undue influence and capacity, change of beneficiary and Texas.

Transamerica Premier Life Ins. Co. v. Guy (E.D. La. 2021)

• E.D. La. No. 2:18-cv-07993
• Order and reasons June 28, 2021; final judgment Sept. 20, 2021
• Louisiana law
• Convicted beneficiary disqualified

Facts

This is the same family as Standard v. Guy. The father and mother each had accidental death coverage under the same group certificate, and neither had named a beneficiary, so the certificate paid the "first surviving class": spouse, children, parents, siblings, then the insured's estate. The insurer filed its interpleader in August 2018, after the son was charged and before he was convicted, and deposited the disputed benefits. The court stayed the case in May 2019 pending the criminal case and lifted the stay in January 2021. With the claimants' consent, $10,000 of the fund went to the insurer for fees and costs, and it was discharged.

Simultaneous death

Both death certificates gave the same time of death, leaving "no record evidence that either spouse survived the other," so the court applied La. R.S. 22:911: "the proceeds of the policy shall be distributed as if the insured had survived the beneficiary, unless otherwise expressly provided in the policy." Neither spouse took the other's benefit, and the court moved to the next classes (at 14–15).

Holding

Under La. R.S. 22:901(D)(1)(a), a beneficiary "[h]eld by a final judgment of a court of competent jurisdiction to be criminally responsible for the death" of the insured takes nothing. A conviction is a "final judgment" even while an appeal is pending (at 16–17). The son argued that disqualifying him before his appeal ended violated due process. Weighing the Mathews v. Eldridge factors, the court disagreed: "it does not violate procedural due process to disqualify an insurance beneficiary based only on his criminal conviction, even if that conviction has not yet been affirmed on direct appeal," and "Louisiana has an interest in applying its slayer rule to provide for the prompt disposition of insurance benefits; allowing the rule to attach immediately upon a conviction furthers that interest" (at 22). His as-applied challenge failed too, because "[c]onclusory say-so is not enough to meaningfully dispute, let alone prove, a constitutional violation" (at 23). Under the certificate, "the remaining children in the class" took the son's share of the father's benefit, and the son took nothing (at 26).

A gap in proof

The mother's benefit would have gone next to her own mother, who survived her but had since died. The court would not award it to the mother's siblings until they showed, with evidence and authority, who was entitled through their late mother's succession (at 26–30). After supplemental briefing, it granted their motion.

Outcome

The final judgment awarded the father's daughters $48,302.21 plus 25.32% of the interest, and one of the mother's siblings, as administrator of their late mother's succession, $142,531.12 plus 74.68% of the interest, each after deducting a pro rata share of the insurer's $10,000 fee, and with interest net of the registry fee.

Why it matters

In Louisiana, a conviction disqualifies a beneficiary under the insurance code without waiting for the appeal, and a federal court has rejected a due-process challenge to that rule. Claimants who inherit through someone who died after the insured still need to prove the chain of entitlement.

Court copies: order and reasons, June 28, 2021, ECF No. 63 (PDF); order granting supplemental motion, Sept. 20, 2021, ECF No. 65; final judgment, ECF No. 66 (PDF); stay order, May 14, 2019, ECF No. 19; order lifting stay, Jan. 21, 2021, ECF No. 26; discharge order, Feb. 19, 2021, ECF No. 39. See also Louisiana.

• D. Conn.
• No. 3:20-cv-00798 (CSH)
• Sept. 28, 2021
• Default judgment; Rule 22 interpleader

Facts

The insured's former wife told the insurer that she would challenge two forms that had changed the beneficiary of his $120,000 policy to his widow, and the widow claimed the benefit too. The insurer filed a Rule 22 interpleader, deposited the benefit and moved to be released from liability; the widow crossclaimed against the former wife. The former wife was served at her home under Connecticut law and never appeared, and the clerk entered her default. A magistrate judge recommended default judgment for the widow, a discharge and $2,000 in fees for the insurer. No one objected.

Holding

The district judge reviewed the recommendation more closely anyway. He confirmed diversity jurisdiction, which a Rule 22 case needs (at 3), and discharged the insurer with prejudice (at 4–5, 8). He refused the injunction against other suits that the insurer sought: "injunctive relief is neither necessary nor appropriate here," because a discharge decree "would be sufficient to resolve the matter" if another suit were filed (at 5–6). He also refused the $2,000 fee. A dispute between "a deceased individual's ex-wife and widow" was "an unremarkable legal tale—even, perhaps, a paradigmatic example of when interpleader is appropriate," and with one claimant in default, the insurer's counsel "hardly have needed to exert themselves" (at 7). Because the former wife had "abandoned her claim," the widow received the deposit with accrued interest, less applicable taxes, fees and expenses (at 7–8).

Why it matters

Unopposed requests can still be cut back. In a Rule 22 case, a court may treat the discharge as protection enough and decline to add an injunction, and courts in the Second Circuit often deny an insurer fees for a routine beneficiary dispute. Compare Farmers New World Life v. Gathright, another default ruling.

American General Life Ins. Co. v. Grohs, No. 3:20-cv-00798 (CSH) (D. Conn.) (Haight, J.): recommended ruling (Sept. 1, 2021, ECF No. 29); order on recommended ruling (Sept. 28, 2021, ECF No. 30), court order (PDF). See also the normal-course-of-business exception and what the discharge covers.

• D. Idaho
• No. 1:20-cv-00036-JZ, Doc. 77
• Dec. 27, 2021
• Judge Jack Zouhary
• Bench trial; Idaho law

Facts

The insured bought a $1 million policy in 2016 and named his then-wife. They divorced in September 2017, and she was still the named beneficiary when he died in May 2019. Early in 2019 his girlfriend printed a change form and filled in its first page, naming herself. The insured had the separate signature page notarized weeks later without the first page, and the notary testified that he said he was unsure who the beneficiary would be. The insurer received the two pages in April 2019. The first page lacked the insured's name, the policy number and the date, and the handwriting on the two pages differed. The insurer sent a "Missing Information Letter" asking him to complete the form. He never did. After his death the insurer treated the former wife as the designated beneficiary, so under Idaho Code § 15-2-804 the benefit would go to his estate. The girlfriend claimed the proceeds, and the insurer filed this interpleader. The court denied cross-motions for summary judgment and held a bench trial.

Holding

The court applied the Idaho rule that, where a policy specifies how to change beneficiaries, "a change of beneficiary can be accomplished only in the manner pointed out in the policy," subject to substantial compliance, which requires proof that the insured intended the change and did everything "to the best of his abilities" (at 5). On intent, the form was incomplete, several witnesses credibly testified that the relationship had cooled and that the insured planned to name his mother and children, and the weight of the evidence showed that "any such intent was abandoned prior to his death" (at 6–9). On effort, the insured was presumed under the mailbox rule to have received the insurer's letter more than five weeks before he died, and nothing showed he was prevented from returning a corrected form (at 9–10). "The Change Form was ineffective under both Banner's terms, and the substantial-compliance doctrine. Under Idaho law, [the insured's] estate is the proper beneficiary of the Policy proceeds" (at 11).

Why it matters

An incomplete change form will rarely survive, especially when the insurer flags the defect and the insured does not fix it. Intent at one point in time is not enough if the evidence shows it was later abandoned. The case also shows Idaho's revocation-on-divorce statute redirecting a forgotten former-spouse designation to the estate. Compare American General v. Maharajh.

Memorandum opinion: court copy (PDF), also on GovInfo. See also Idaho and change of beneficiary.

• W.D. Tex.
• No. 1:21-cv-00721-RP
• Report May 2, 2022; adopted July 27, 2022
• Default judgment

Facts

The insured's husband was the primary beneficiary of her group life coverage, and her mother was the contingent beneficiary. The magistrate judge's report states that the husband killed the insured in April 2021 and that he was in prison. The insurer interpleaded, explaining that a beneficiary "cannot collect a death benefit" by killing the insured. The mother answered; the husband never responded, and the clerk entered his default.

Holding

Recommending default judgment for the mother, the magistrate judge quoted the rule that "[w]hen only one of the claimants named in an interpleader action has answered, the court need not consider the merits of which party is entitled to the funds." The court therefore did not have to apply a slayer statute to award the fund.

Outcome

The insurer was discharged on May 2, 2022, with its fees paid from the fund, and the discharge order provided that no further proceedings would be filed until the criminal matter against the husband was resolved. The district judge adopted the recommendation and entered a take-nothing default judgment against the husband on July 27, 2022. The registry funds, with all accrued interest, went to the mother, and a final judgment followed on October 11, 2022.

Why it matters

A beneficiary accused of causing the insured's death who does not answer loses by default. The remaining claimant does not have to prove the slayer case.

Symetra Life Ins. Co. v. Broderick, No. 1:21-cv-00721-RP (W.D. Tex.): report and recommendation (PDF), order adopting it (PDF), default judgment (PDF), amended disbursement order, final judgment (PDF). The discharge order (ECF No. 19) is cited by docket number. See also the slayer rule.

• N.D. Ga.
• No. 1:22-cv-01117-TWT
• Feb. 14, 2023
• Georgia law; summary judgment

Facts

In 2019 the insured bought a $1,000,000 life insurance policy naming his two children as equal primary beneficiaries. On May 28, 2021, the insurer received a change form that kept each child at 35% and added four other beneficiaries for the remaining 30%. He died on June 1, 2021. The insurer then received his 2009 divorce settlement agreement, which required him to "maintain a life insurance policy on his life with a death benefit of $1,000,000.00, naming the children as beneficiaries and the Wife as Trustee for the benefit of the children as long as he shall be obligated to pay child support hereunder." The insurer paid $700,000 plus interest to a trust for the children, interpleaded the remaining $300,000, deposited $320,165.99 with interest, and was discharged. The children's side argued that the divorce agreement gave them a vested interest in the whole policy; the four added beneficiaries relied on the change.

Holding

Applying Georgia law, the court recognized that a divorce decree requiring a parent to keep insurance for the children can give them a vested interest that a later change cannot defeat, but only in the policy the decree covers. The 2009 agreement referred to "a" policy, and the court held that nothing in its language "can be interpreted to refer to a particular insurance policy—much less the Policy that the Deceased purchased almost 10 years after the Divorce Agreement was finalized." The rule that a replacement policy carries the children's interest did not help, because the only evidence of an earlier policy was inadmissible hearsay, and, as the court put it, "[a]gain, the Divorce Agreement refers only to "a" life insurance policy." It granted summary judgment for the four added beneficiaries and directed the clerk to pay them the fund, with interest, in the shares the change form gave them.

Why it matters

A divorce agreement that requires "a" policy, without identifying one, may not stop the insured from changing the beneficiaries of a policy bought years later. Children relying on a divorce obligation need admissible evidence tying the policy at issue to the decree. Compare American General v. Martin.

Midland National Life Ins. Co. v. Villalobos, No. 1:22-cv-01117-TWT (N.D. Ga.) (Thrash, J.): deposit order (Aug. 2, 2022, ECF No. 33); discharge judgment (Aug. 2, 2022, ECF No. 34), court order (PDF); opinion and order granting summary judgment (Feb. 14, 2023, ECF No. 45), court order (PDF) (entered again as ECF No. 46). See also divorce and Georgia.

• M.D. Ga.
• No. 5:22-cv-348 (MTT)
• Sept. 6, 2023; disbursement Oct. 17, 2023; judgment Jan. 4, 2024
• ERISA

Facts

An employee enrolled in life coverage under her employer's ERISA plan but named no beneficiary. In that case the plan paid first to a "spouse or domestic partner," then to children. Her fiancé claimed as her domestic partner. One way to qualify under the plan required a domestic partner declaration "completed and Signed by the Employee," and there was no evidence she had signed one; he submitted a declaration he signed himself. The claims administrator, MetLife, first accepted his claim, reversed after an appeal by the insured's son, and then denied his claim. He sued. MetLife brought the competing claimants into the case by interpleader, deposited the benefit and was dismissed. The court ordered the plan's administrative record filed before deciding the claim.

Holding

Reviewing the decision de novo, the court held that the fiancé was not a domestic partner under the plan, because the required declaration had to be signed by "the Employee," meaning the insured. That he also worked for the same employer did not make his own signature enough; as the court put it, he "cannot grant to himself that insurable interest after [her] death." On October 17, 2023, the court directed the clerk to disburse $482,013.56, plus all accrued interest less the registry fee, to the insured's son, and judgment was entered in his favor on January 4, 2024.

Why it matters

When an ERISA plan has no named beneficiary, its own definitions and paperwork decide who is next in line. An informal relationship does not qualify without the documents the plan requires.

Zaharopoulos v. Taylor, No. 5:22-cv-348 (MTT) (M.D. Ga.) (Treadwell, C.J.): order to file the administrative record (Oct. 20, 2022, ECF No. 10); order on the claims (Sept. 6, 2023, ECF No. 43), govinfo.gov (PDF); disbursement order (Oct. 17, 2023, ECF No. 46); judgment (Jan. 4, 2024, ECF No. 47), court judgment (PDF) (also on govinfo.gov (PDF)). Other orders, including the deposit and discharge order (ECF No. 26), are cited from the court record and not linked. See also federal programs.

• W.D.N.Y.
• No. 1:22-cv-00611-LJV-LGF
• February 27, 2024
• Summary judgment

Facts

In 2014 the insured bought a life insurance policy naming the woman he later married as primary beneficiary and his nephew as successor beneficiary. The couple married in 2016. In May 2021 they signed a separation and property settlement agreement, which was incorporated into their June 2021 divorce judgment. Neither document mentioned the policy or required him to keep life insurance. One clause provided that if he died first, any amounts due to her under the agreement that remained unpaid would be a creditor's claim against his estate, paid first from "any life insurance policy in effect at the time of death." He died in August 2021 without changing the designation, and a death benefit of $99,992.54 became payable. The insurer interpleaded the former wife and the nephew, and the court dismissed it after ordering it to pay the benefit to the clerk of court.

Holding

Under New York's EPTL 5-1.4, a divorce revokes a revocable beneficiary designation of the former spouse unless a governing instrument expressly provides otherwise. Governing instruments include a court order and a property-division agreement between the spouses. Neither the separation agreement nor the divorce judgment expressly provided that she would receive the death benefit. The clause on unpaid amounts covered only debts that were past due at death, and she offered no evidence of any. She argued that future child support was an amount due, but child support ends at death unless the parties agree otherwise, and nothing in the agreement extended it. Her evidence that the insured wanted her to receive the benefit could not overcome the statute's automatic effect. It made no difference that she was named before the marriage. The court granted summary judgment for the nephew and directed the clerk to disburse the death benefit to him.

Why it matters

In New York, a former spouse keeps a pre-divorce designation only if the divorce papers or another governing instrument say so expressly, or if the insured names her again after the divorce. A general reference to life insurance, or evidence of what the insured intended, is not enough.

State Farm Life & Accident Assurance Co. v. Hobin, No. 1:22-cv-00611-LJV-LGF (W.D.N.Y. Feb. 27, 2024): decision and order (PDF); judgment (PDF). Copies of the court's filed orders. See also New York.

• N.D. Cal.
• No. 4:23-cv-04680-DMR
• October 28, 2024
• Undue influence

Facts

The insured held two life insurance policies with the insurer. Beneficiary change requests submitted online in February 2022, which the insurer confirmed by endorsements mailed to him, named one claimant, described on the forms as his domestic partner and his fiancée, as 100% primary beneficiary of both policies and named his cousin as contingent beneficiary. The insured had been in and out of the hospital in early 2022 and died in March 2022. The primary beneficiary sued the insurer for the benefits in the Southern District of Iowa on August 9, 2022. The insurer interpleaded the cousin, who disputed the recent changes. On January 30, 2023, the Iowa court allowed the deposit, discharged the insurer and enjoined further suits against it, with each side bearing its own fees. On May 15, 2023, it dismissed the cousin's cross-claim under California's elder financial abuse statute for lack of particular facts, observing that "[t]hese bare allegations simply track the statutory elements for financial abuse under California law." On September 11, 2023, it transferred the case to the Northern District of California under 28 U.S.C. § 1404(a), where it was decided by a magistrate judge.

Holding

The court applied California's two-step approach. The primary beneficiary met her initial burden by showing that the last recorded designations named her, so the burden shifted to the cousin to prove undue influence, incapacity or fraud. He disavowed fraud and did not argue incapacity. Weighing the four factors in California's statutory definition of undue influence (Welf. & Inst. Code § 15610.70), the court found disputes of fact on the insured's vulnerability and on the claimant's apparent authority, but no evidence of any actions or tactics by her. The cousin pointed to irregularities in the forms and argued identity theft, but did not connect her to them, did not obtain the records he said would support his theory and produced no documents in discovery. He also offered no evidence on the equity of the result. The court granted summary judgment and directed payment of the benefits on deposit, plus accrued interest, to the primary beneficiary. The court wrote that the cousin "did not come forward with any evidence connecting Sands to these or other purportedly nefarious actions" (slip op. at 10). The Ninth Circuit affirmed in an unpublished memorandum, Sands v. Norman, No. 24-7237 (Dec. 15, 2025). The majority held that the cousin "failed to make any coherent legal argument or identify any issues of material fact that could invalidate the last recorded beneficiary designation," and that he "affirmatively waived any theory of fraud." One judge dissented: "In my view, there is a genuine issue of material fact over whether Sands exerted this undue influence and whether Baxley's late changes to the beneficiary designations reflected his true intent." In the dissent's words, "[a]t bottom, this is a dispute that turns on the credibility of the various witnesses." The court denied rehearing on January 29, 2026.

Why it matters

Suspicion is not enough. An undue influence claim needs evidence of what the influencer actually did, and the party making it has to gather that evidence in discovery. The dissent shows that judges can disagree about how much circumstantial evidence is enough. Compare Thrivent v. Bressler, above, under Arizona law.

Sands v. Midland National Life Ins. Co., No. 4:22-cv-00259 (S.D. Iowa): interpleader and discharge order (Jan. 30, 2023); order dismissing the cross-claim (May 15, 2023), court order (PDF); transfer order (Sept. 11, 2023). No. 4:23-cv-04680-DMR (N.D. Cal.): order granting summary judgment (Oct. 28, 2024, ECF No. 85), court order (PDF) (also on govinfo.gov (PDF)); judgment (ECF No. 86), court judgment (PDF). Sands v. Norman, No. 24-7237 (9th Cir.): memorandum (Dec. 15, 2025), court copy (PDF) (also on the Ninth Circuit site (PDF)); order denying rehearing (Jan. 29, 2026). See also California and undue influence and capacity.

• N.D. Ill.
• No. 1:22-cv-04422
• Dec. 3, 2024
• Illinois law

Facts

In 2005 the insured bought a life insurance policy with a $100,000 death benefit, naming his then-wife as beneficiary. They divorced in 2006, and he never removed her. He died in 2022 without naming an alternative beneficiary. His former wife and his children from other relationships all claimed the death benefit. The insurer filed an interpleader, explaining that it could not tell whether Illinois's revocation-on-divorce provision, which the court noted became effective in 2019, applied to a 2006 divorce.

Holding

Under Illinois law, a statute that says nothing about retroactivity applies to earlier events only if it is procedural. The court held that 750 ILCS 5/503(b-5) is substantive, because it strips former spouses of contractual and property rights to death benefits and overrides policyholders' own choices, so it did not apply to the 2006 divorce. The court found Sveen v. Melin inapplicable, because it decided only that retroactive application of such a statute is constitutional, not whether Illinois's statute applies retroactively. The children's separate challenge to the validity of the marriage failed for lack of any supporting evidence, even though discovery had been open. The former wife was entitled to the interpleaded funds.

Why it matters

A revocation-on-divorce statute may not reach a divorce entered before the statute took effect. Check the dates before assuming a statute removed a former spouse.

American General Life Ins. Co. v. Martin, No. 1:22-cv-04422 (N.D. Ill.): corrected deposit order (Sept. 9, 2022, ECF No. 11); discharge order (May 5, 2023, ECF No. 58); memorandum opinion and order (Dec. 3, 2024, ECF No. 75), court order (PDF) (also on Justia); judgment (ECF No. 76), court judgment (PDF). The court set the summary judgment briefing schedule on May 5, 2023, and its status orders in 2024 recorded the motion as under advisement; the ruling came about 19 months after that schedule was set. See also Illinois and divorce.

• M.D. Tenn.
• No. 3:23-cv-00805
• Mar. 6, 2025
• California law

Facts

The insured and her husband had named each other as primary beneficiaries of their life insurance policies; hers was a $250,000 policy. A March 2020 change form made their daughter the primary beneficiary of the insured's policy, with the husband as secondary beneficiary. After the insured died, the husband said the daughter had forged the signatures, and the insurer paid the proceeds into the court's registry. The insurer's own review concluded that the signatures were not authentic. The daughter, who represented herself, did not answer requests for admission asking her to admit that she had signed her parents' names. A funeral-financing company that had advanced funeral and burial costs held an assignment from both claimants.

Holding

Under Federal Rule of Civil Procedure 36, the unanswered requests were deemed admitted, which conclusively established the facts. Applying California law, because the contract was made in California, the court held that the forged change form was void and granted summary judgment for the husband. "The Court finds that the record is sufficient to show that Monique committed forgery," it wrote, and "[i]t is undisputed that neither George nor Janice signed the March 12, 2020, beneficiary change request form." With all parties' agreement, it first ordered payment to the funeral-financing company under the assignment. It directed the clerk to disburse the $242,730.96 in the court's registry, which included accrued interest: $35,692.47 to the funeral-financing company and $207,038.49 to the husband, each plus any additional interest.

Why it matters

A forged change form has no effect, and the earlier designation controls. The case also shows that ignoring requests for admission in an interpleader can decide the case against the party who stays silent.

Everlake Life Ins. Co. v. Lomax, No. 3:23-cv-00805 (M.D. Tenn.) (Crenshaw, J.): order granting interpleader relief and discharge (June 10, 2024, ECF No. 36); clerk's deposit report (June 26, 2024, ECF No. 38); order clarifying the deposit (July 24, 2024, ECF No. 41); memorandum opinion and order granting summary judgment and disbursement (Mar. 6, 2025, ECF No. 45), court order (PDF) (also on govinfo.gov (PDF)). See also change of beneficiary.

• W.D. Wis.
• No. 3:24-cv-00214-wmc
• Apr. 16, 2025; judgment Apr. 25, 2025
• ERISA plan; summary judgment

Facts

An employee died in January 2024 with no designated beneficiary for her group life coverage. When no beneficiary is named, the plan pays the "first of the following: your (a) surviving spouse or domestic partner; (b) surviving child(ren) in equal shares (c) surviving parents in equal shares; (d) surviving siblings in equal shares; (e) estate." Her only child sued the insurer under ERISA. The insurer deposited the benefit, was discharged, and brought in her roommate, who had submitted an "affidavit of domestic partnership."

Holding

The roommate moved to withdraw and was dismissed with prejudice, but the court still decided the child's motion on the merits, because "a district court cannot grant a summary judgment motion simply because it is unopposed" (quoting Boyd v. Sheffler, No. 23-1596 (7th Cir. Mar. 29, 2024)). It noted that "different-sex domestic partnerships are not recognized in Wisconsin, Wis. Stat. § 770.05(5)," and held that the evidence did not meet the plan's other definition of domestic partner. Interpleader claimants "must recover on the strength of their own claims rather than on the weakness of adverse ones," and the child showed that he was the insured's only child.

Outcome

Judgment for the child for the death benefit plus any accrued interest, about 12 months after the case was filed.

Why it matters

When no beneficiary is named, the plan's default order decides, and a claimant must fit the plan's definitions. Even an unopposed claimant must prove entitlement.

Jones v. Prudential Ins. Co. of America, No. 3:24-cv-00214-wmc (W.D. Wis.): opinion and order (PDF), judgment (PDF), interpleader and discharge order. See also federal programs and Wisconsin beneficiary law.

• W.D. Okla.
• No. 5:25-cv-00359-HE
• Aug. 18, 2025
• Default judgment; Rule 22 interpleader

Facts

The insured died on June 7, 2024. On March 28, 2025, his life insurer filed an interpleader against two claimants: the insured's two minor children, through their parent as next friend, and the insured's surviving spouse. The children's parent answered on April 21, 2025 and claimed the death benefit for them. The spouse never answered, and the clerk entered her default on June 2, 2025. This is a ruling on a default, not a decision on the competing claims.

Holding

Jurisdiction (June 2, 2025): the case was filed as a statutory interpleader, but the two claimants were not diverse from each other. The court converted it to rule interpleader because "while the requirements for statutory interpleader under 28 U.S.C. § 1335 are not satisfied due to the lack of diversity between defendants [the two claimants], the court retains subject matter jurisdiction under 28 U.S.C. § 1332," and ordered the insurer to deposit the $600,000 policy proceeds plus interest (ECF No. 15). The clerk received $607,191.00. Service (June 25, 2025): setting the default motion for hearing, the court noted that "[a]lthough the 'green card' reflects a signature not obviously hers," other evidence suggested the spouse had been served. Because that evidence showed "some uncertainty on [her] part as to how she is to respond," it directed that she be sent the hearing order at least ten days in advance (ECF No. 20). Default and discharge (July 8, 2025): after the hearing, the court granted default judgment, ordering that the spouse "shall take nothing from the life insurance policy proceeds" (ECF No. 23). In a separate order it discharged and dismissed the insurer with prejudice and permanently enjoined the claimants from suing it over the policy, relying on the Anti-Injunction Act's "necessary in aid of [the federal court's] jurisdiction" exception (ECF No. 24). Payment (Aug. 18, 2025): after a hearing on how the children's share would be held (ECF No. 26), the court directed the clerk to pay the $607,191.00 principal, plus interest earned less the registry fee, to a trust established exclusively for the two minor children, to be held until they reach the age of majority (ECF No. 29).

Why it matters

A missing element of § 1335 does not necessarily end a federal interpleader when ordinary diversity jurisdiction exists. The case also shows a court checking service before entering default when a certified-mail receipt is doubtful, and examining how a minor's share will be held before releasing it. The court did not decide the spouse's claim on its merits; it ended because she did not answer. Compare Reliance Standard v. Coleman.

Everlake Assurance Co. v. Taylor, No. 5:25-cv-00359-HE (W.D. Okla.) (Heaton, J.): order converting to Rule 22 interpleader and granting deposit (June 2, 2025, ECF No. 15); order setting hearing (June 25, 2025, ECF No. 20); order granting default judgment (July 8, 2025, ECF No. 23), court order (PDF); order of discharge and permanent injunction (July 8, 2025, ECF No. 24); final judgment and order of interpleader disbursement (Aug. 18, 2025, ECF No. 29), court judgment (PDF). The July 14, 2025 hearing order (ECF No. 26) is cited from the court record and not linked. See also statutory vs. Rule 22 and minor children.

• W.D. Tex.
• No. 6:25-cv-00094-LS
• October 10, 2025
• Annuity; default judgment

Facts

According to the insurer's complaint, two people jointly owned an annuity, and the named beneficiaries were three children of the surviving owner. After the other owner died in June 2024, the surviving joint owner asked to be paid the death benefit. The insurer told him he was not the listed beneficiary and asked the claimants to agree; they did not all sign. The insurer filed a statutory interpleader under 28 U.S.C. § 1335 in March 2025. The surviving joint owner answered; none of the three named beneficiaries did, and the clerk entered their defaults on April 23, 2025. This is a default ruling, not a decision on the merits of the competing claims.

Holding

First motion (August 2025): the surviving joint owner moved for default judgment against his co-defendants. The court observed that "Rule 55 provides, however, that a 'plaintiff' may apply for default judgment," and that the motion cited "no statutory, circuit court, or Supreme Court authority for the proposition that a defendant may seek a default judgment against co-defendants in an interpleader action." "[I]n an abundance of caution," it denied the motion with leave to amend, and offered the two appearing parties the alternative of a joint motion for an order and judgment (ECF No. 18). Default judgment (October 2025): on the renewed request, the court ordered that the surviving joint owner "is entitled to a default judgment against" the three named beneficiaries "such that they take nothing from the disputed annuity contract proceeds at issue in this action" (ECF No. 26).

Outcome

The insurer had not yet deposited the money. Three days after the default judgment, the court ordered it to move for leave to deposit, noting that under § 1335(a)(2) "the plaintiff must deposit the money or property in dispute into the registry of the court. Plaintiff has not yet done so" (ECF No. 27). On October 23, 2025, the court allowed the deposit, less an agreed fee, and discharged and dismissed the insurer upon receipt. On November 3, 2025, it ordered $202,327.22 in the registry, plus all accrued interest less the registry's administrative fee, paid to the surviving joint owner, and entered final judgment.

Why it matters

Named beneficiaries can lose their share simply by not answering, even when the contract names them. The case also shows that courts differ on whether one claimant can use Rule 55 against co-claimants: compare American General Life Ins. Co. v. Wilson (N.D. Fla. 2023), where the court said that "[g]enerally, interpleader defendants can utilize Rule 55 when other parties fail to defend," and Reliance Standard v. Coleman, where the court entered default judgment on the answering claimant's motion. A claimant seeking default judgment against co-defendants may need to show authority for it. See named in an interpleader.

Athene Annuity & Life Co. v. Hernandez, No. 6:25-cv-00094-LS (W.D. Tex.): clerk's entries of default, ECF Nos. 12, 12-1, 12-2 (Apr. 23, 2025); order denying motion for default judgment with leave to amend, ECF No. 18 (Aug. 27, 2025), court order (PDF); default judgment, ECF No. 26 (Oct. 10, 2025), court order (PDF); order to move for deposit, ECF No. 27 (Oct. 13, 2025) (cited by docket number); order granting interpleader of proceeds and discharge, ECF No. 29 (Oct. 23, 2025); order of interpleader disbursement, ECF No. 32 (Nov. 3, 2025); final judgment, ECF No. 33 (Nov. 3, 2025), court order (PDF). The description of the claims comes from the insurer's complaint (ECF No. 1), a party filing. See also Texas and annuities.

• N.D. Fla.
• No. 4:25-cv-168-AW-MAF
• January 23, 2026
• ERISA; post-distribution claim

Facts

After the insured died, the insurer received competing claims to life insurance proceeds under a policy governed by ERISA, and it interpleaded the funds. The insured's former girlfriend was the sole beneficiary named on his enrollment form. His mother crossclaimed against her, alleging that the designation was invalid because it was incomplete, forged, procured by undue influence or fraud, or contrary to what the insured later told family members. In the alternative, she sought a constructive trust in favor of his estate. The named beneficiary moved for judgment on the pleadings.

Holding

The court held that the mother had not alleged facts supporting any challenge to the designation. Undue influence and forgery were bare assertions, fraud was not pleaded with particularity, she alleged no step the insured took to change the designation, and the gaps on the form did not invalidate it. So the funds were properly the named beneficiary's under the ERISA-governed policy, which "resolves this interpleader action." The court read the constructive trust count as an unjust enrichment claim and, citing Kennedy and the Eleventh Circuit's Akpele decision, said post-distribution challenges "present different questions." It said the proper outcome appeared to be paying the funds to the named beneficiary and dismissing the unjust enrichment claim without prejudice to a new state-law action, but it invited optional briefs on whether the claim was appropriate before distribution and took no further action until then.

Why it matters

It squarely raises whether a state-law claim against the named beneficiary can be decided in the interpleader before distribution, and shows a court in the Eleventh Circuit inclined to say no under Akpele. This site has not located a public record of any later ruling on that claim. See ERISA post-distribution claims.

United of Omaha Life Ins. Co. v. Black, No. 4:25-cv-168-AW-MAF (N.D. Fla. Jan. 23, 2026), order regarding motion for judgment on the pleadings, ECF No. 44, court order (PDF).

• S.D. Tex.
• No. 4:25-cv-06165
• Signed April 27, 2026; entered April 28, 2026
• Power of attorney; default judgment

Facts

According to the companies' interpleader complaint, the insured's son was named 100% beneficiary of a whole life policy and a variable annuity in September 2022. On November 29, 2024, about a week before the insured died, the companies received online requests naming another claimant, the insured's wife as the son's filings describe her, as 100% primary beneficiary of both. She later sent the companies a power of attorney naming her as the insured's agent and wrote that he had directed the change. The son disputed the changes, at first on the ground that the insured lacked capacity and later on the ground that the Louisiana power of attorney did not authorize the agent to name herself, relying on Transamerica Advisors v. Marsch. On December 11, 2025, the son sued the insurer in the same court; eight days later the companies filed this interpleader under 28 U.S.C. § 1335 and Rule 22, and the son's own suit was dismissed on his notice of voluntary dismissal. The other claimant did not answer, and the clerk entered her default on March 3, 2026.

Holding

On the son's motion, the court found that he "has demonstrated default judgment is appropriate in this case," granted the motion, and ordered that the other claimant "shall take nothing from the life insurance proceeds in this case." The one-page order does not discuss the power of attorney, capacity or any state's law.

Outcome

On May 15, 2026, with the son's consent, the court allowed the companies to deposit the amount payable under both contracts, less an agreed fee, enjoined the claimants from bringing other actions for payment under the policy or the annuity, and dismissed the companies with prejudice. In a disbursement order signed July 17, 2026 and entered July 26, 2026, the court ordered $246,755.81 in the registry, plus all accrued interest less the registry's administrative fee, paid to the son, and dismissed the case upon disbursement.

Why it matters

A claimant whose designation depends on a change made under a power of attorney still has to answer the interpleader; here the default ended her claim before any court looked at the agent's authority. Because the court applied no law, the case is not authority on Louisiana powers of attorney; for that question see Marsch and Louisiana. The case also shows a claimant's own lawsuit giving way to the insurer's interpleader; see when a claimant sues first.

New York Life Ins. Co. v. Anderman, No. 4:25-cv-06165 (S.D. Tex.): clerk's entry of default, ECF No. 13 (Mar. 3, 2026); order granting default judgment, ECF No. 20 (signed Apr. 27, 2026, entered Apr. 28, 2026), court order (PDF); order granting motion to deposit and for discharge, ECF No. 22 (May 15, 2026); order of interpleader disbursement, ECF No. 24 (signed July 17, 2026, filed July 22, 2026, entered July 26, 2026). The son's earlier suit is Anderman v. New York Life Ins. Co., No. 4:25-cv-05959 (S.D. Tex.), order of dismissal, ECF No. 8 (Dec. 23, 2025). The description of the claims comes from the parties' filings. See also Texas.

• N.D. Ala.
• No. 5:25-cv-1904-CLS
• May 13, 2026
• Brokerage TOD account
• Late change; forgery and undue influence alleged but untested
• Default forfeiture; 2025 TOD operative

Facts

According to the firm's amended complaint, the owner opened a transfer-on-death brokerage account in 2007, worth about $10.25 million as of September 30, 2025. A 2023 TOD agreement left it 40%, 40% and 20% to three people. A new TOD agreement signed August 4, 2025 left it 70%, 10%, 10% and 10% to four people; only one person was named in both, and that person's share fell from 20% to 10%. The owner died on September 17, 2025. The firm transferred the account under the 2025 form into accounts it held for the four 2025 beneficiaries, and let the beneficiary named in both forms withdraw 10%. One of the two people dropped in 2025 then emailed the firm, "claiming forgery, undue influence, coercion, and manipulation." The firm interpleaded all six claimants under 28 U.S.C. § 1335. The beneficiary named in both forms did not dispute the 2025 form and claimed only 10%. The 2025 beneficiaries cross-claimed for a declaration that the 2025 form controls, and the other person dropped in 2025 filed a late answer to the cross-claims saying she did not contest it. The challenger was personally served but did not answer, and the clerk entered her default; about three months after service she moved to set it aside.

Deposit and discharge

In April 2026 the court held that the firm had not met the statute's deposit-or-bond requirement and questioned a proposed $1,000 bond. It then ordered a $90,000 bond, which the firm posted on May 11, 2026, satisfying "all jurisdictional requirements of 28 U.S.C. § 1335." The firm was discharged from liability to the claimants upon the bond's deposit (slip op. at 2–3 & n.3).

Holding

The court refused to set aside the challenger's default. Her delay was not excused by a family death, and she offered no meritorious defense: she said only that she disputed the change, but "the movant must present a factual basis for [her] claim" (at 13–15). Applying the rule that "[a] named interpleader defendant who fails to answer the interpleader complaint and assert a claim to the res forfeits any claim of entitlement that may have been asserted," the court entered default judgment and held that she forfeited any claim to the account (at 18–19). It granted judgment on the pleadings against the other two claimants, adopted the 2025 beneficiaries' statement of the controlling law, and held that "[t]he revised, 2025 Transfer on Death Agreement is the operative designation of beneficiaries," with the account paid by the 2025 percentages (at 19–21).

Outcome

A separate judgment was entered with the opinion. The firm's request for its fees and costs, which the 2025 beneficiaries did not oppose, was to be set by later order and deducted from the accounts (at 21–22). This site has not located the fee ruling.

Why it matters

The forgery and undue influence allegations were never tested on evidence. The challenger lost because she did not answer or give facts, not because the court found the 2025 form genuine and freely made. The case also shows a firm that had already moved a TOD account internally under the later form before a challenge arrived, and a court that accepted a bond well below the account's value instead of requiring a full deposit. Compare Reliance Standard v. Coleman and Harris v. Wiggins.

Raymond James & Associates, Inc. v. Medina, No. 5:25-cv-1904-CLS (N.D. Ala. May 13, 2026), memorandum opinion, ECF No. 55, court opinion (PDF), also on GovInfo (PDF); order on deposit or bond, ECF No. 49 (Apr. 28, 2026); bond order, ECF No. 53 (May 6, 2026). The facts come from the firm's amended complaint (PDF), ECF No. 4, as summarized in the opinion. See also brokerage accounts, undue influence and capacity and Alabama.

• C.D. Cal.
• No. 2:25-cv-10327-PA-MAR
• June 17, 2026
• Summary judgment

Facts

The insured's divorce judgment, which incorporated a property settlement agreement, awarded the life insurance policy (face amount $200,000 since a 1999 reduction) to his former wife as her separate property and required her to keep paying its monthly premiums. After the divorce he filed a series of beneficiary designations that reduced and then removed her share. The last one, in January 2025, named several of his children, his girlfriend and another former wife. The former wife kept paying premiums, at first by automatic debit and later through amounts the insured withheld from the monthly divorce payments he owed her. He died in 2025. The two insurers interpleaded the proceeds and, by stipulation, deposited them and were discharged. The other claimants crossclaimed against the former wife.

Holding

The crossclaimants did not file the statement of genuine disputes the court's local rules require, so the court treated the former wife's facts as admitted. It also refused to delay the ruling for more discovery, because they offered no declaration, no specific facts and no showing of diligence. The crossclaimants did not dispute that the divorce judgment gave her ownership of the policy. Their argument that she had paid only part of the premiums would at most support a reimbursement claim by the insured's estate, which was not a party, and the only issue before the court was the proper beneficiary. The court granted summary judgment for the former wife and concluded that she is entitled to the entire interpleaded fund. In a later order (July 1, 2026) it entered default judgment against a claimant who had been served but never appeared.

Why it matters

Here a divorce judgment that awarded the policy itself to the former spouse, which no one disputed, decided the case despite the insured's later beneficiary changes. The case also shows that claimants who skip the court's summary-judgment procedures can have the other side's facts treated as undisputed.

Protective Life Ins. Co. v. Tello, No. 2:25-cv-10327-PA-MAR (C.D. Cal.): order granting stipulation for deposit, discharge and dismissal (filed May 12, 2026, ECF No. 56); civil minutes granting motion for summary judgment (June 17, 2026), court order (PDF). The July 1, 2026 default judgment is cited from the court record and not linked. See also named in an interpleader.

• E.D. Mich.
• No. 2:25-cv-10964-TGB-EAS
• June 23, 2026
• Annuity; default judgment

Facts

The decedent owned an annuity whose death benefit was payable to his daughter, the named primary beneficiary. After his death in September 2024, his estate submitted a competing claim. On April 3, 2025, the estate sued the insurer for a declaratory judgment that it was entitled to the death benefit, saying in the alternative that it would consent to converting the case to an interpleader. The insurer answered and filed a counterclaim and third-party complaint in interpleader against the estate and the daughter. The estate answered. The insurer could not find the daughter despite attempts at three addresses, conversations with apartment complex employees, residents and neighbors, and calls to phone numbers associated with her, so the court allowed service by publication for three consecutive weeks in a newspaper. She never appeared, and the clerk entered her default on October 22, 2025. The insurer then moved, unopposed, for default judgment, leave to deposit the benefit, a discharge and an agreed fee. This is a ruling on an unopposed default motion, not a contested decision on the merits of the estate's claim.

Holding

Default: citing Eastern District of Michigan and Southern District of Ohio decisions, the court said that a named interpleader defendant who fails to answer "forfeits any claim of entitlement that might have been asserted," and that "[i]f only one interpleader defendant remains following the default of another defendant, the remaining defendant is entitled to the fund." Because the daughter was served by alternate means and never responded, she "has forfeited her right to pursue an interest in the Death Benefit," and her interest was terminated (pp. 6–7). Interpleader: the insurer invoked Rule 22, diversity jurisdiction existed, and a named beneficiary plus a competing claim by the estate exposed it to multiple liability. Applying the Sixth Circuit's two-stage framework from United States v. High Technology Products, 497 F.3d 637 (6th Cir. 2007), the court found at the first stage that interpleader was properly invoked (pp. 8–10). Fees: under Holmes v. Artists Rights Enforcement Corp., 148 F. App'x 252, 259 (6th Cir. 2005), the insurer met all four requirements, and an agreed $9,000 in fees and costs was reasonable given the work involved, including the service efforts, and because a death benefit of $605,283.77 "will not be unreasonably depleted" (pp. 11–13). The court ordered the insurer to deposit the remaining $596,283.77, plus any interest, within 21 days, discharged it upon deposit from further liability to the daughter, dismissed with prejudice any claims relating to the annuity that the parties could have asserted against it, and allowed the estate to move for disbursement. The order states it "is not a final order and does not close the case" (pp. 13–14). It amended an order entered June 2, 2026 (ECF No. 22). On August 21, 2026, granting the estate's unopposed motion, the court ordered the deposited fund paid to the estate and the case dismissed with prejudice upon disbursement (ECF No. 25).

Why it matters

A named beneficiary who cannot be found, or who ignores an interpleader, can lose the benefit by default even though the designation was never set aside. The court never ruled on the merits of the estate's competing claim; the daughter's default decided it. The case also shows a claimant's own lawsuit turning into an interpleader through the insurer's counterclaim, and the kind of modest, agreed fee courts approve when a stakeholder steps aside.

Estate of Budinski v. AAA Life Ins. Co., No. 2:25-cv-10964-TGB-EAS (E.D. Mich.): amended order granting the insurer's unopposed motion for default judgment and interpleader relief (June 23, 2026, ECF No. 24), court order (PDF); order granting unopposed motion for interpleader disbursement and dismissing case (Aug. 21, 2026, ECF No. 25). See also when a claimant sues first, annuities and attorneys' fees.

• N.D. Ala.
• No. 7:26-cv-00239-EGL
• August 20, 2026
• Judgment on the pleadings

Facts

In 1999 the insured, then living in Alabama, bought a $150,000 life insurance certificate from a fraternal benefit society and named his then-wife as principal beneficiary. They divorced in Alabama in 2003. No party pointed to any provision of the divorce judgment addressing the certificate, and he never changed the designation. He remarried later that year, moved to Oklahoma and died there in 2025. His former wife claimed the proceeds as the named beneficiary. His widow claimed them as surviving spouse, arguing that the divorce had revoked the designation by operation of law. The insurer interpleaded the proceeds, and the widow also brought crossclaims against the former wife for sanctions and abuse of process, interference with contract and unjust enrichment, and fraud.

Holding

Under Alabama's rule that the law of the place where a contract was made governs it, the court applied Alabama law: the insured applied for the certificate in Alabama, and it named no governing law. It rejected the argument that Oklahoma law should control because the insured died domiciled there, noting that no Alabama authority was cited for measuring a beneficiary's rights by the insured's domicile at death. Alabama's revocation-on-divorce statute, Ala. Code § 30-4-17, took effect on September 1, 2015, about twelve years after this divorce, and unlike the statutes of states such as Nevada and Florida it has no retroactivity clause. The Alabama Supreme Court in Blalock v. Sutphin had called the statute a "prospective default rule." As the court put it: "Two words in that holding are key. The rule is ‘prospective,’ and it is triggered by ‘divorce.’" The 2003 divorce therefore did not revoke the designation, and the court declared that the former wife is entitled to the certificate's proceeds. It dismissed the widow's crossclaims for sanctions and abuse of process, interference with contract and unjust enrichment, and fraud with prejudice, observing that "[a] party who answers a complaint that names her as a defendant has done only what the federal rules require of her." Costs on the crossclaim were taxed against the widow. The insurer was discharged with an injunction under 28 U.S.C. § 2361 and bore its own fees and costs; as the court noted, "The fund will therefore pass to the prevailing claimant undiminished." After both claimants waived appeal, the court's disbursement order directed the clerk to pay the full proceeds on deposit, $151,808.64 (the death benefit plus interest to the date of deposit), plus all interest accrued in the registry, less the registry fee, to the former wife.

Why it matters

Whether a revocation-on-divorce statute reaches an older divorce depends on the state and on the date of the divorce, not just the date of death. Compare Sveen v. Melin, where Minnesota applied its statute to an earlier policy, and American General v. Martin, where Illinois's provision did not reach a divorce entered before it took effect. The case also shows that answering an interpleader and pressing a claim to the fund is not sanctionable conduct.

Modern Woodmen of America v. Harris, No. 7:26-cv-00239-EGL (N.D. Ala. Aug. 20, 2026): order granting deposit; memorandum opinion and order (PDF); final judgment (PDF); disbursement order. Copies of the court's filed orders. See also Alabama.

• D. Kan.
• No. 2:25-cv-02587-HLT-GEB
• September 1, 2026
• Default judgment; competing spouses

Facts

An employee covered by a group life policy his employer obtained died on October 13, 2024. He had designated the claimant who filed a claim as his wife as sole beneficiary. His daughter challenged that claim on the ground that the couple had divorced, and later disclaimed any interest. A second claimant told the insurer that the named beneficiary was not the insured's legal wife and that she was. The insurer interpleaded both women. The named beneficiary answered; the second claimant waived service but never answered, and the clerk entered her default on April 23, 2026. This is a ruling on a default, not a decision on the competing marriage claims.

Holding

The insurer's motion (June 2026): the insurer had filed a motion for default judgment along with its request for entry of default. The court explained that "[t]ypically, a motion for default judgment is premature until the clerk enters default. See Fed. R. Civ. P. 55 (providing a two-step process)." The motion also took no position on the competing claims and gave no basis for judgment, so the court denied it without prejudice and set July 31, 2026, as the deadline for a default-judgment motion (ECF No. 13). The named beneficiary's motion (September 2026): "Interpleader defendants can utilize Rule 55 when other parties fail to defend," and "[a] defendant who fails to answer forfeits any interest in the funds." Because the amount was certain, no hearing was needed: "In most interpleader cases, a hearing under Rule 55(b)(2) is unnecessary because the amount at issue is certain." The court found jurisdiction under 28 U.S.C. § 1335 and personal jurisdiction through the statute's nationwide service of process, held that the second claimant's "failure to answer forfeits any interest" in the proceeds, and stated that "[t]he entry of default judgment terminates" her claim. It directed the insurer to pay the named beneficiary directly and then file a stipulation of dismissal or other appropriate motion (ECF No. 16, pp. 2–3).

Why it matters

The court did not decide whether the couple had divorced, which woman was the insured's legal wife, or whether ERISA applied or preempted any state rule. Nothing in the orders suggests the second claimant's account was false; her claim ended only because she did not answer. The case also shows the two steps of Rule 55: default first, then a supported motion for judgment, ideally by the claimant who wants the money. Compare Prudential v. Iturbide and Estate of Budinski v. AAA Life.

Reliance Standard Life Ins. Co. v. Coleman, No. 2:25-cv-02587-HLT-GEB (D. Kan.): order denying the insurer's motion for default judgment without prejudice (signed June 25, 2026, filed June 26, 2026, ECF No. 13), court order (PDF); order granting default judgment (Sept. 1, 2026, ECF No. 16), court order (PDF). See also divorce and named in an interpleader.