Hearing v. Minnesota Life Insurance Co.

793 F.3d 888 (2015)

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Nature of the Case

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Facts

Pursuant to a decree upon a divorce from his wife, Jon Holloway purchased a life insurance policy in the amount of $100,000 from Minnesota Life Insurance Company in 1998. The divorce decree required Jon to maintain a life insurance policy payable to his children until his child support obligations ended. Jon designated his sister, P, beneficiary of the policy. The policy application stated that Jon was 'naming his sister as the beneficiary so ex-wife can't control the death proceeds.' Jon's child support obligations ended no later than 2008. Jon's life insurance policy contains the following language: “If you have reserved the right to change the beneficiary, you can file a written request with us to change the beneficiary. . . . Your written request will not be effective until we record it in our home office. After we record it, the change will take effect as of the date you signed the request. However, if the insured dies before the request has been so recorded, the request will not be effective as to those death proceeds we have paid before your request was so recorded.” When Jon died a handwritten note dated September 18, 2012, addressed to 'Nikki' and signed by Jon was found on or near his body. The note expressed Jon's love for Nikki, directed her to 'sell everything you don't want and bank it,' and said, 'Chris would like the 44 Back The Rest you Get.' At the end, the note listed the policy number for the Minnesota Life insurance policy and the name and telephone number of the insurance agent. Nikki submitted the note to Minnesota Life after Jon's death and claimed a right to the proceeds of the policy. Minnesota Life advised Nikki and P of their competing claims. The district court permitted Minnesota Life to deposit the funds with the court and dismissed the company from the action. The court granted summary judgment for P, reasoning that Jon did not take adequate steps to change the beneficiary from P to Nikki under the policy's change-of-beneficiary requirements.