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Maine: Beneficiary Disputes and Interpleader Under Maine Law

Maine's slayer rule requires a killing that is both felonious and intentional, so a plea to an unintentional homicide does not settle the question, as a federal court in Idaho held when an employer plan chose Maine law.

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On this page
  1. Maine’s best federal slayer case was decided in Idaho
  2. Divorce
  3. Fees for the insurer
  4. Federal law in Carlton
  5. Decisions
  6. Related guides

Maine’s best federal slayer case was decided in Idaho

The most useful recent federal decision on Maine’s slayer rule did not come from the District of Maine. Unum Life Insurance Co. of America v. Smith was decided by the U.S. District Court for the District of Idaho. The insured worked for an employer whose group plan named Maine as its governing law, and the court honored that choice-of-law clause rather than applying Idaho’s similar statute.1

As quoted in Smith, Maine’s Probate Code provides that one “who feloniously and intentionally kills the decedent forfeits all benefits under this Article with respect to the decedent’s estate . . . .” Absent a conviction, “the court, upon the petition of an interested person, shall determine whether, under the preponderance of evidence standard, the individual would be found criminally accountable for the felonious and intentional killing of the decedent.”1

The named beneficiary in Smith had been charged with murder and later pleaded guilty to involuntary manslaughter. The insured’s estate argued that the conviction ended his claim. The court disagreed: “Accordingly, Smith only has a conviction for the felonious and unintentional killing of his wife. His conviction does not preclude him from inheriting under the Maine Probate Code, and it is not proper to grant summary judgment to Holley on this basis.”2 The estate could still try to prove an intentional killing by a preponderance at trial.

Compare Hawaii, where a federal court treated a manslaughter conviction as an intentional killing under Hawaii law. The difference comes from each state’s criminal definitions, not from the slayer statutes themselves.

Divorce

18-C M.R.S. § 2-804 is Maine’s revocation-by-divorce section, and § 2-803 addresses the effect of a criminal conviction.3 Editors confirmed the headings but did not rely on their text for this page, so their terms are not summarized here. See divorce and beneficiary designations.

Fees for the insurer

In Churchill, the insured changed her beneficiary from her daughter to her son three days before she died, and the insurer interpleaded a $10,000 policy. The court discharged the insurer but denied its fee request. It explained that “Underlying this rationale is the precept that insurance companies are uniquely positioned to allocate the ordinary costs of doing business among their policyholders.”4 See attorney’s fees in interpleader.

Federal law in Carlton

Carlton involved SGLI coverage. The insured’s foster parents opposed payment to his fiancée, the designated beneficiary, and raised undue-influence and related allegations. The court granted her summary judgment: “In short, federal law commands the payment of proceeds to which Cross is legally entitled.”5 Maine law did not decide the outcome. See federal programs.

Decisions

Unum Life Ins. Co. of Am. v. Smith (D. Idaho 2025)

  • No. 1:23-cv-00426-DCN, Dkt. 64
  • Chief Judge David C. Nye, District of Idaho
  • Decided Apr. 16, 2025
Facts
Group life and accidental-death benefits under an employer plan that chose Maine law. The named beneficiary pleaded guilty to involuntary manslaughter.
Holding
The conviction was for an unintentional killing and did not bar him; summary judgment for the estate was denied and the question left for trial.
Why it matters
Under the uniform-code wording, the offense of conviction matters, and a civil court may still decide intent.

Opinion: GovInfo.

American General Life Ins. Co. v. Churchill (D. Me. 2006)

  • No. CV-06-61-B-W, Doc. 18
  • Judge John A. Woodcock Jr.
  • Decided Oct. 16, 2006
Facts
A late beneficiary change between the insured's adult children led the insurer to interplead.
Holding
Discharge granted; fees denied (slip op. at 4).
Why it matters
In a routine case, an insurer may bear its own fees.

Opinion: GovInfo.

Carlton v. Prudential Ins. Co. of Am. (D. Me. 2009)

  • No. 08-cv-170-P-S, Doc. 31
  • Judge George Z. Singal
  • Decided Feb. 4, 2009
Facts
SGLI coverage designating the insured's fiancée. Family members challenged payment to her.
Holding
Summary judgment for the designated beneficiary (slip op. at 4).
Why it matters
SGLI's order of precedence controls over state-law objections.

Opinion: GovInfo.

Footnotes

  1. Unum Life Ins. Co. of Am. v. Smith, No. 1:23-cv-00426-DCN, slip op. at 4–5 (D. Idaho Apr. 16, 2025) (quoting 18-C M.R.S. § 2-802(2), (7)). GovInfo. Statute: Maine Legislature. ↩ ↩2

  2. Smith, slip op. at 7. ↩

  3. 18-C M.R.S. §§ 2-803, 2-804 (headings). § 2-803; § 2-804 (Maine Legislature). ↩

  4. American General Life Ins. Co. v. Churchill, No. CV-06-61-B-W, slip op. at 4 (D. Me. Oct. 16, 2006). GovInfo. ↩

  5. Carlton v. Prudential Ins. Co. of Am., No. 08-cv-170-P-S, slip op. at 4 (D. Me. Feb. 4, 2009). GovInfo. ↩