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Connecticut: Beneficiary Disputes and Interpleader Under Connecticut Law

Connecticut's starting rule is that a beneficiary change must follow the policy's procedure, with substantial compliance as the fallback, and its constructive-trust remedy has limits when a divorce agreement supplies its own remedy.

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On this page
  1. Changing a beneficiary: strict rule, equitable fallback
  2. Divorce agreements and constructive trusts
  3. Slayer statute
  4. Decisions
  5. Related guides

Changing a beneficiary: strict rule, equitable fallback

Connecticut’s rule has two layers. The first is strict. Quoting the Connecticut Supreme Court, the District of Connecticut has said that “a change of beneficiary of an insurance policy can be effected only by following the procedure prescribed by the policy.”1

The second layer is equitable. “Under Connecticut state law, when an insurance policyholder does not comply strictly with a policy’s requirements for changing beneficiaries of their life insurance policy, the doctrine of substantial compliance determines whether the change should nonetheless be given effect.”2 The leading state case is Engelman v. Connecticut General Life Insurance Co., 240 Conn. 287 (1997).

In practice, both federal decisions below sent the question to trial. In Pagan, the insurer had told the insured his change form was deficient, and what he meant to do afterward was disputed. In Degner, the claim of a change was tied up with a spouse’s power of attorney during the insured’s serious illness.

Divorce agreements and constructive trusts

A promise in a dissolution agreement to keep life insurance for a former spouse is common. Whether it can reach the proceeds is a different question. In Bakx, no beneficiary was designated on the policy and the former wife relied on such a promise. The court did not decide whether ERISA preempted her theory, because “even under Connecticut law, she is not entitled to a constructive trust.”3 Relying on a 2023 Connecticut Appellate Court decision, it reasoned that the agreement supplied its own remedy.

Editors did not verify a Connecticut statute revoking a former spouse’s insurance designation on divorce, so this page does not describe one. See divorce and beneficiary designations.

ERISA plans

Where the coverage is an employer plan, ERISA's plan-documents rule may control before state law is reached. Bakx involved an ERISA plan and avoided the preemption question only because the claim failed under state law too. See ERISA post-distribution claims and federal programs.

Slayer statute

Conn. Gen. Stat. § 45a-447 is titled for persons convicted of certain crimes being ineligible to receive insurance or annuity proceeds as the victim’s beneficiary.4 Editors confirmed the heading but not the operative text, so this page does not summarize the elements. See the slayer rule guide.

Decisions

Metropolitan Life Ins. Co. v. Bakx (D. Conn. 2026)

  • No. 3:23-cv-1474 (KAD), ECF 76
  • Judge Kari A. Dooley
  • Decided Mar. 30, 2026
Facts
No beneficiary was designated on a $480,000 policy. The former wife relied on the dissolution agreement; the surviving spouse's bankruptcy trustee also claimed the proceeds.
Holding
Summary judgment for the trustee. No constructive trust under Connecticut law (slip op. at 9).
Why it matters
A divorce promise does not automatically become a claim to the proceeds.

Opinion: GovInfo.

West Coast Life Ins. Co. v. Degner (D. Conn. 2024)

  • No. 3:22-cv-00443 (VDO), ECF 77
  • Judge Vernon D. Oliver
  • Decided Sept. 24, 2024
Facts
The insured was seriously ill and her husband held her power of attorney. Her daughter claimed that a beneficiary change had been made.
Holding
Summary judgment was granted on the tort cross-claims and otherwise denied; substantial compliance was left for the trier of fact. The court noted that "[U]nder Connecticut law, a party does not abuse the legal process merely by filing suit." (slip op. at 14).
Why it matters
Family members suing one another over a change rarely win on tort theories alone.

Opinion: GovInfo.

Jackson Nat'l Life Ins. Co. v. Pagan (D. Conn. 2020)

  • No. 3:19-cv-01205 (JBA), Doc. 59
  • Judge Janet Bond Arterton
  • Decided Sept. 2, 2020
Facts
The insurer told the insured his change form was deficient. His second wife claimed the change should be honored anyway.
Holding
Her motion for summary judgment was denied because the insured's intent after the rejection was disputed.
Why it matters
An insurer's rejection notice can become key evidence of what the insured did, or failed to do, next.

Opinion: GovInfo.

Footnotes

  1. West Coast Life Ins. Co. v. Degner, No. 3:22-cv-00443 (VDO), slip op. at 9 (D. Conn. Sept. 24, 2024) (quoting Bigley v. Pacific Standard Life Ins. Co., 642 A.2d 4, 7 (Conn. 1994)). GovInfo. ↩

  2. Jackson Nat’l Life Ins. Co. v. Pagan, No. 3:19-cv-01205 (JBA), slip op. at 4–5 (D. Conn. Sept. 2, 2020). GovInfo. ↩

  3. Metropolitan Life Ins. Co. v. Bakx, No. 3:23-cv-1474 (KAD), slip op. at 9 (D. Conn. Mar. 30, 2026). GovInfo. ↩

  4. Conn. Gen. Stat. § 45a-447 (heading). Connecticut General Assembly, chapter 802b. ↩