Signed but Never Filed Form Won't Help Widow
ST. LOUIS (CN) - The 8th Circuit has ruled against a widow whose late husband never submitted the insurance form designating her as sole beneficiary.
Dennis Hall signed a beneficiary form naming his wife, Jane Hall, as his sole beneficiary in November 2010, but he never turned in the form.
After Dennis Hall died from cancer early in 2011, Metropolitan Life Insurance Co denied Jane Hall's claim, stating that Dennis Hall II was the beneficiary to the policy.
Jane Hall appealed the ruling and informed MetLife of the beneficiary form that he signed - but never turned in, as well as the statement in Dennis Hall's will that said his entire estate, including his life-insurance policies, were to go to Jane Hall.
After losing that appeal, Jane Hall sued MetLife and Dennis Hall II in Minnesota state court.
The declaratory-judgment action was removed to federal court where a judge granted MetLife summary judgment, finding that the insurer acted reasonably because the beneficiary form had not been filed within 30 days as required by the policy. Since wills cannot directly dispose of a non-probate asset, the court also found that it did not effect a change in beneficiary.
A three-judge panel of the 8th Circuit affirmed Thursday.
"We conclude that MetLife reasonably determined that the will was inadequate
to effect a change in beneficiary," Judge Steven Colloton wrote for the court. "Dennis's will addressed bequests from his estate. The estate was not a beneficiary of the policy, and Dennis's will - unlike the will in Liberty Life Assurance Co. of Boston v. Kennedy - did not expressly address the distribution of assets that were not part of the estate. Although Dennis's will directed that '[a]ny and all life insurance and benefits shall be distributed to Jane Marie Hall,' that command followed shortly after the direction 'that the following specific bequests be made from my estate.' It was thus reasonable for MetLife to construe the will to address only life insurance proceeds that were property of the estate. MetLife did not abuse its discretion simply because the will might be amenable to an alternative interpretation."
Chief Judge William Jay Riley and Judge Jane Kelly concurred with Colloton in the 10-page opinion.