Ronald Zulkiewski had a life insurance policy when he died, but because beneficiary changes had been made on the policy before his death, his mother and his wife disputed the rights to the insurance proceeds. The dispute centered on whether the last beneficiary change (made online using the insurance company's online service program) was made by the insured, and whether there were sufficient safeguards in place to allow a finding that the change was authentic and attributable to Zulkiewski. In this article, reprinted from the UK-based E-Commerce Law Report (Vol. 12, Issue 5, 2012), Margo Tank analyzes the (unpublished) decision of the Michigan Court of Appeals, which ultimately held that no question of fact was created by the insured's mother about the authenticity of the beneficiary change. Ms. Tank also includes references to other recent cases involving the validity of electronic signatures.
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