The BNA Tax and Accounting Center is the only planning resource to offer expert analysis and practice tools from the world's leading tax and accounting authorities along with the rest of the tax...
Tulio D. Chirinos, Esq.
Proskauer Rose LLP, New Orleans, LA
Circuit held that the named beneficiary of an
ERISA-governed life insurance policy was entitled to the proceeds
even though the decedent's will named a different beneficiary.
Hall v. Metro. Life Ins. Co., No. 13-1332, 2014 BL 128209
(8th Cir. May 8, 2014). Dennis Hall, the decedent, while employed,
obtained a life insurance policy issued by MetLife and named his
son, Dennis Hall II, as the sole beneficiary. Hall subsequently
married Jane Hall but never added her as a beneficiary of the life
insurance plan. Although he completed and signed a
beneficiary-designation form naming Jane as the sole beneficiary,
he never submitted the form to MetLife. After being informed
that he had little time to live, Hall executed a will stating that
all life insurance and benefits should be distributed to Jane Marie
Hall. Hall died shortly thereafter.
Jane Hall filed a claim with MetLife for the life
benefits based on the terms of Dennis Hall's will. MetLife
denied her claim and distributed the life insurance proceeds to
Dennis Hall II as the sole beneficiary. The court determined that
MetLife reasonably concluded that the will was inadequate to effect
a change in beneficiary because the will only addressed life
insurance proceeds that were the property of the estate and the
estate was not a beneficiary of the life insurance policy. The
court also found that the beneficiary-designation form that Hall
signed but never submitted did not satisfy the plan's requirement
because it was not submitted within 30 days of being signed. In so
ruling, the court rejected Jane Hall's argument that the 30-day
requirement was not valid because it did not appear in the summary
plan description. The court reasoned that an unambiguous provision
in the plan document prevails over a silent SPD. The court also
rejected Jane Hall's argument that the federal common law doctrine
of substantial compliance effected a change of beneficiary.
Proskauer's Perspective: The Eighth Circuit's ruling is
consistent with well-established principles including that valid
ERISA plan beneficiary designation forms control the distribution
of plan benefits; and the terms of the plan document are
more information, in the Tax Management Portfolios, see
Wagner, 374 T.M., ERISA - Litigation, Procedure, Preemption
and Other Title I Issues.
© 2014 Proskauer Rose LLP. All Rights Reserved.
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to email@example.com.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to firstname.lastname@example.org.
Put me on standing order
Notify me when new releases are available (no standing order will be created)