The Eighth Circuit held that the named beneficiary of an ERISA governed life insurance policy was entitled to the proceeds even though the decedent’s will named a different beneficiary. Hall v. Metro. Life Ins. Co., 2014 U.S. App. LEXIS 8652 (8th Cir. May 8, 2014). Dennis Hall, the decedent, obtained a life insurance policy issued by MetLife and named his son, Dennis Hall II, as the sole beneficiary. Hall subsequently married Jane Hall but never added her as a beneficiary of the life insurance plan. Although he completed and signed a beneficiary-designation form naming Jane as the sole beneficiary, he never submitted the form to MetLife. After being informed that he had little time to live, Hall executed a will stating that all life insurance and benefits should be distributed to Jane Marie Hall. Hall died shortly thereafter.
Jane Hall filed a claim with MetLife for the life insurance benefits based on the terms of Dennis Hall’s will. MetLife denied her claim and distributed the life insurance proceeds to Dennis Hall II as the sole beneficiary. The court determined that MetLife reasonably concluded that the will was inadequate to effect a change in beneficiary because the will only addressed life insurance proceeds that were the property of the estate and the estate was not a beneficiary of the life insurance policy. The court also found that the beneficiary-designation form that Hall signed but never submitted did not satisfy the plan’s requirement because it was not submitted within 30 days of being signed. In so ruling, the court rejected Jane Hall’s argument that the 30-day requirement was not valid because it did not appear in the summary plan description. The court reasoned that an unambiguous provision in the plan document prevails over a silent SPD. The court also rejected Jane Hall’s argument that the federal common law doctrine of substantial compliance effected a change of beneficiary.
Proskauer’s Perspective: The Eighth Circuit’s ruling is consistent with well-established principles including that valid ERISA plan beneficiary designation forms control the distribution of plan benefits; and the terms of the plan document are controlling.