interpleader.com
Guides

Basics

What can be interpleaded

If you are involved

Beneficiary disputes

Law and sources

Talk to an attorney

State law

Arkansas: Beneficiary Disputes and Interpleader Under Arkansas Law

Arkansas beneficiary fights in federal court have turned on substantial compliance and capacity, and an Eighth Circuit decision from an Arkansas case limits when an insurer can use interpleader as a shield.

By

On this page
  1. What makes Arkansas different
  2. Changing a beneficiary: substantial compliance
  3. Capacity and undue influence
  4. When the insurer is part of the problem
  5. Statutes editors checked
  6. Decisions
  7. Related guides

What makes Arkansas different

Most of the Arkansas decisions collected here are about process, not statutes. Two questions keep recurring: did the insured do enough to change the beneficiary, and did the insurer’s own handling of the claim help cause the dispute?

Changing a beneficiary: substantial compliance

In Woodall, the parties agreed Arkansas law applied. The court explained that “Arkansas follows the doctrine of substantial compliance, which dictates that where “the insured has done everything reasonably possible to effect a change in beneficiary, a court of equity will decree that to be done which ought to be done.””1 It found that the insured met that standard and awarded the proceeds to his widow rather than to the former wife still named on the policy.

The doctrine cuts both ways. It rescues a change the insured clearly tried to complete, but it does not turn an unexpressed wish into a designation. See change of beneficiary.

Capacity and undue influence

In Estate of Williams, the insured named her boyfriend shortly after a hospital discharge, and her estate challenged the designation. The court started from the rule that “Arkansas law presumes that every person is “sane, fully competent, and capable of understanding the nature and effect of [their] contracts.””2 It granted summary judgment to the boyfriend, finding that the insured “had sufficient mental capacity, was not unduly influenced or coerced, and followed the proper process laid out by the Policy” to designate him.3

When the insurer is part of the problem

The appeal in Woodall, decided as Primerica Life Ins. Co. v. Reid, matters well beyond Arkansas. The district court had dismissed the widow’s counterclaims against the insurer. The Eighth Circuit reversed: “if the party asserting the right to interpleader, here Primerica, has acted unfairly to create the underlying conflict necessitating interpleader relief, then that party may not use the interpleader procedure as a shield against counterclaims asserting that the interpleader stakeholder is at fault in creating the subject of the dispute.”4 See discharge, fees, and interest.

Statutes editors checked

  • Ark. Code § 28-11-204 provides that a spouse convicted of first- or second-degree murder of the other spouse “shall not be endowed in the real or personal estate of the decedent spouse.”5 It is a dower and curtesy provision.
  • Divorce. Editors did not find an Arkansas statute that revokes a former spouse’s life insurance designation on divorce. Treat this as unverified, and check the policy terms and any divorce decree.

Decisions

Primerica Life Ins. Co. v. Woodall (E.D. Ark. 2019)

  • No. 4:17CV00272 SWW, Doc. 92
  • Judge Susan Webber Wright
  • Decided June 3, 2019
Facts
The insured's former wife was the named beneficiary. His widow said he had tried to change the designation to her.
Holding
The insured substantially complied with the policy's change provision (slip op. at 10), so the widow took the proceeds. The court also granted the insurer summary judgment on the widow's counterclaim, a ruling later reversed on appeal.
Why it matters
Substantial compliance can override the name on the policy when the insured's efforts are documented.

Opinion: GovInfo.

Primerica Life Ins. Co. v. Reid (8th Cir. 2020)

  • No. 19-2399
  • Opinion by Judge Grasz
  • Decided Sept. 16, 2020
Facts
The widow who won the proceeds in Woodall appealed the dismissal of her counterclaims against the insurer.
Holding
Reversed. An interpleading insurer that acted unfairly to create the conflict cannot use interpleader to bar counterclaims that it caused the dispute (slip op. at 5).
Why it matters
Discharge is not automatic when the stakeholder's own conduct is in question.

Opinion: GovInfo.

Protective Life Ins. Co. v. Estate of Williams (W.D. Ark. 2026)

  • No. 6:25-cv-06030-SOH, ECF 58
  • Judge Susan O. Hickey
  • Decided Apr. 6, 2026
Facts
The insured named her boyfriend as beneficiary shortly after a hospital discharge. Her estate challenged the designation for lack of capacity and undue influence.
Holding
Summary judgment for the boyfriend on the proceeds.
Why it matters
The presumption of competence is hard to overcome without specific evidence about the insured's condition when the form was signed.

Opinion: GovInfo.

Footnotes

  1. Primerica Life Ins. Co. v. Woodall, No. 4:17CV00272 SWW, slip op. at 8 (E.D. Ark. June 3, 2019). GovInfo. ↩

  2. Protective Life Ins. Co. v. Estate of Williams, No. 6:25-cv-06030-SOH, slip op. at 8 (W.D. Ark. Apr. 6, 2026). GovInfo. ↩

  3. Estate of Williams, slip op. at 10. ↩

  4. Primerica Life Ins. Co. v. Reid, No. 19-2399, slip op. at 5 (8th Cir. Sept. 16, 2020). GovInfo. ↩

  5. Ark. Code Ann. § 28-11-204(a) (2025). Justia. ↩