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A deceased Fiat Chrysler worker made the unusual move of listing himself as the beneficiary of his own life insurance policy. As a result, his daughter will receive $64,000 in benefits ( Metro. Life Ins. Co. v. Brown , 2017 BL 141171, E.D. Mich., No. 2:16-cv-10500-DPH-APP, 4/28/17 ).
Charles A. Brown listed himself and his daughter as equal primary beneficiaries of the $64,000 life insurance policy he received through Fiat Chrysler. A federal judge on April 28 awarded Brown’s daughter the full amount of his policy, despite a competing claim from Brown’s father, Charles H. Brown.
The elder Charles Brown argued that he was the intended joint beneficiary of his son’s policy but for a “typographical mistake” as to his middle initial. The judge disagreed: “While it is odd, perhaps absurd, for a participant to designate himself (or his estate at a time when there is no estate and the beneficiary of a future estate is unknown) as beneficiary of his own life insurance policy, it does not follow that the Designation Form and other Plan documents should be ignored.”
The judge found it important that the beneficiary designation form contained a space for listing the beneficiary’s relationship to the policyholder. The younger Charles Brown wrote “Daughter” next to his daughter’s name, but he left the space next to his own name blank, the judge said. This cast doubt on the elder Brown’s claim to benefits, the judge said.
Finding that the worker intended to list himself—and not his father—as an equal primary beneficiary, the judge looked to a policy provision establishing rules for when a policyholder dies with no surviving beneficiary. These rules favored the daughter, who was the unmarried worker’s only child, the judge said. As a result, the daughter will receive all benefits payable under the policy.
Chief Judge Denise Page Hood of the U.S. District Court for the Eastern District of Michigan wrote the decision.
Simen Figura represented the elder Charles Brown. Fedor Camargo & Weston PLC represented the daughter.
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Text of the decision is at http://www.bloomberglaw.com/public/document/Metro_Life_Ins_Co_v_Brown_No_1610500_2017_BL_141171_ED_Mich_Apr_2.
Copyright © 2017 The Bureau of National Affairs, Inc. All Rights Reserved.
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