RICHMOND, Va. (CN) – Metropolitan Life Insurance did no wrong when it paid death benefits to the estranged husband of a deceased South Carolina woman – even though he had waved any claim to the benefits in a separation agreement, the 4th Circuit ruled.
The ruling affirms a decision by Senior District Judge C. Weston Houck, of the District of South Carolina, in a case filed by the dead woman’s mother and son.
Emma C. Boyd was an employee of Delta Airlines and participated in a life insurance plan administered by MetLife. The plan allowed her to designate a beneficiary, and also gave her the right to unilaterally change the designated beneficiary at any time by sending a signed and dated request to the insurance company.
When she joined the program in December 2001, Boyd designated her husband, Robert Alsager, as the primary beneficiary of the plan, and designated her mother, Mary Emma Boyd, as the contingent beneficiary n the event that Alsager refused to take the benefits.
Six years later, Boyd and Alsager separated, and in April 2008, entered a separation and property-settlement agreement. A provision of that agreement released Boyd and Alsager’s claims to the other’s estate or property.
In spite of this agreement, Boyd never changed the beneficiary designation on file with MetLife. When she died on Nov. 8, 2008, the Boyds filed a claim for the benefits from the life-insurance policy, as did Alsager, despite his having signed the settlement agreement.
Relying on the plan documents on file, MetLife determined that the benefits should be paid to Alsager and denied the Boyds’ claim. In oral arguments before the lower court, MetLife indicated that it subsequently paid the benefits to Alsager.
A three-judge panel of the federal appeals court said it leaned heavily on the 2009 decision for Kennedy v. Plan Administrator for DuPont Savings & Investment Plan, in which the U.S. Supreme Court concluded that a claim for benefits must stand or fall by the terms of the plan.
Writing for the panel, Circuit Judge J. Harvie Wilkinson III said Kennedy both announced what is now known as the “plan-document rule” and “also confirmed the rule’s soundness through application.”
“We see no need and possess no warrant to unwind Kennedy and make a puzzle of plan administration … inasmuch as MetLife did what the law required it to do, the case against it must be dismissed and the judgment of the district court must be affirmed,” Wilkinson wrote.