Justia Insurance Law Opinion Summaries

Donna Miller Bruenger, the ex-wife of the late Coleman Miller, filed a petition for declaratory judgment against Courtenay Ann Miller, Coleman’s daughter, seeking entitlement to Coleman’s Federal Employee’s Group Life Insurance (FEGLI) benefits. Coleman had failed to designate a beneficiary for his FEGLI benefits before his death, and MetLife distributed the benefits to Courtenay. Bruenger argued that Coleman’s legal obligation under a Qualified Domestic Relations Order (QDRO) to assign her the benefits should prevail.The Jefferson Circuit Court ruled against Bruenger, concluding that federal law precluded her claim because Coleman’s employer did not receive the QDRO before his death. Bruenger’s subsequent appeal was dismissed by the Court of Appeals as untimely, and the court also imposed sanctions for filing a frivolous appeal. Bruenger then sought relief under CR 60.02, which the trial court granted, allowing her to refile the appeal. The Court of Appeals dismissed the refiled appeal as frivolous and awarded attorney’s fees to Courtenay.The Supreme Court of Kentucky reviewed the case and determined that the Court of Appeals had jurisdiction to consider the merits of the CR 60.02 relief. The Supreme Court held that RAP 11(B) authorizes the award of attorney’s fees as a sanction for frivolous appeals but found that the imposition of sanctions in this case violated due process because Bruenger was not given notice or an opportunity to be heard. The Supreme Court affirmed the dismissal of the appeal for lack of jurisdiction but reversed the sanctions imposed by the Court of Appeals. View "BRUENGER V. MILLER" on Justia Law

Renee Sevelitte and the Estate of Joseph F. Sevelitte dispute the entitlement to the proceeds of a life insurance policy Joseph purchased during his marriage to Renee. Massachusetts law automatically revokes a spouse's beneficiary status upon divorce unless specific exceptions apply. The life insurance policy named Renee as the beneficiary, but the policy did not address the effect of divorce on beneficiary status. Renee and Joseph's divorce agreement included provisions about life insurance policies but did not explicitly state that Renee would remain the beneficiary of the policy in question.The United States District Court for the District of Massachusetts granted summary judgment to the Estate, determining that Renee could not establish that any exceptions to the automatic revocation applied. Renee appealed, arguing that the district court erred in its decision.The United States Court of Appeals for the First Circuit reviewed the case. The court noted that its previous decision did not determine that the divorce agreement satisfied the statutory exceptions but only that it was plausible. The court emphasized that Renee needed to provide evidence to support her claim that the divorce agreement intended to maintain her beneficiary status. The Estate presented evidence, including an affidavit from Joseph's divorce attorney and an expert report, indicating that the divorce agreement did not intend to retain Renee's beneficiary status.The First Circuit affirmed the district court's decision, concluding that Renee failed to present any evidence to create a genuine dispute about the intended meaning of the divorce agreement. Therefore, the court held that the Estate was entitled to the proceeds of the life insurance policy. View "Sevelitte v. The Guardian Life Insurance Company of America" on Justia Law

Ian Simpson purchased a life insurance policy from Transamerica Life Insurance Company and named his then-fiancée, Holly Moore, as the primary beneficiary and his father, Jeffrey Simpson, as the contingent beneficiary. After Ian and Holly married and subsequently divorced, Ian died without changing the policy beneficiaries. The divorce decree stipulated that Holly was divested of all rights to Ian's life insurance policies. After Ian's death, both Holly and Jeffrey claimed the policy proceeds, leading Transamerica to file an interpleader action in federal court.The district court ruled in favor of Holly, holding that Texas Family Code § 9.301, which generally strips an ex-spouse of beneficiary interests in insurance policies after a divorce, only applies if the insured and the beneficiary were married when the insurance policy was purchased. The court reasoned that since the policy was purchased before Ian and Holly's marriage, Holly was not considered "the insured's spouse" at the time of the policy's inception, and therefore, the divorce decree did not divest her of the insurance proceeds.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the district court's judgment. The appellate court interpreted § 9.301 to focus on the marital relationship at the time of the divorce decree's rendition, regardless of when the insurance policy was purchased. The court held that since Holly was Ian's spouse at the time of the divorce decree, § 9.301 divested her of her beneficiary interest in the policy. Therefore, the court ruled in favor of Jeffrey Simpson, the contingent beneficiary. View "Simpson v. Moore" on Justia Law

This case involves a dispute between Darren Findling, a professional guardian, and Auto-Owners Insurance Company. Findling was appointed as the guardian for two individuals, Mary Ann Malloy and Dana Jenkins, who were incapacitated due to automobile accidents. Findling, along with employees of his law firm, provided various guardianship services to Malloy and Jenkins, and sought reimbursement from Auto-Owners for these services under the no-fault act. Auto-Owners declined to reimburse for the services performed by the employees of Findling’s law firm, arguing that the services were not lawfully rendered.The Oakland County Probate Court granted Findling’s motions for partial summary disposition, ruling in favor of Findling. Auto-Owners appealed, but the Court of Appeals initially denied the appeal. The Supreme Court then remanded the cases to the Court of Appeals for consideration. On remand, the Court of Appeals affirmed in part and reversed in part, holding that a guardian is only required to comply with certain statutory provisions to lawfully delegate guardianship powers, but not duties, to employees.The Supreme Court of Michigan, in a unanimous opinion, held that a professional guardian cannot, without executing a power of attorney complying with certain statutory provisions, lawfully delegate to employees their final decision-making authority over a guardianship “power” that is explicitly listed in the statute or over any guardianship task that alters or impairs the incapacitated individual’s rights, duties, liabilities, or legal relations. However, a professional guardian may lawfully have employees assist in exercising a guardianship power and may have employees perform any other guardianship task on behalf of the professional guardian. The Supreme Court vacated the decisions of the lower courts and remanded the cases for further proceedings. View "In Re Guardianship Of Mary Ann Malloy" on Justia Law

The case pertains to a marital dissolution dispute in Indiana where the husband's police pension constituted the majority of the couple's marital estate. The husband was reluctant to share his pension with his wife, expressing his intention to disregard any court order mandating him to do so. As a response, the trial court ordered the husband to secure and subsidize a life insurance policy to ensure the wife received her share of the marital estate. The husband challenged the trial court's authority, arguing that the court did not consider the tax implications of his future pension payments.The Indiana Supreme Court upheld the trial court's decision. It ruled that the trial court had broad statutory authority to order a security or other guarantee, such as a life insurance policy, when necessary, to secure the division of property. The court also held that the husband had waived his challenge regarding the tax consequences of his future pension payments.The facts of the case reveal that the husband and wife had been married for nearly twenty-six years. The husband's police pension had a market value of over $1.1 million, constituting over 85% of the marital estate. The husband was unwilling to share his pension with his wife, and the wife expressed concern that she might not receive anything. The trial court ordered the husband to make monthly payments and obtain a life insurance policy that named her as owner and beneficiary. The husband contested this order, leading to the appeal. The Indiana Supreme Court affirmed the trial court's decision, maintaining that the court had the authority to secure the wife's share of the marital estate through a life insurance policy. View "Cooley v. Cooley" on Justia Law

Husband Steven McAnulty was married twice: once to Plaintiff Elizabeth McAnulty, and once to Defendant Melanie McAnulty. Husband's first marriage ended in divorce; the second ended with his death. Husband’s only life-insurance policy (the Policy) named Defendant as the beneficiary. But the Missouri divorce decree between Plaintiff and Husband required Husband to procure and maintain a $100,000 life-insurance policy with Plaintiff listed as sole beneficiary until his maintenance obligation to her was lawfully terminated (which never happened). Plaintiff sued Defendant and the issuer of the Policy, Standard Insurance Company (Standard), claiming unjust enrichment and seeking the imposition on her behalf of a constructive trust on $100,000 of the insurance proceeds. The district court dismissed the complaint for failure to state a claim. Plaintiff appealed. By stipulation of the parties, Standard was dismissed with respect to this appeal. The only question to be resolved was whether Plaintiff stated a claim. Resolving that issue required the Tenth Circuit Court of Appeals to predict whether the Colorado Supreme Court would endorse Illustration 26 in Comment g to § 48 of the Restatement (Third) of Restitution and Unjust Enrichment (Am. L. Inst. 2011) (the Restatement (Third)), which would recognize a cause of action in essentially the same circumstances. Because the Tenth Circuit predicted the Colorado Supreme Court would endorse Illustration 26, the Court held Plaintiff has stated a claim of unjust enrichment, and accordingly reversed the previous dismissal of her case. View "McAnulty v. McAnulty, et al." on Justia Law

Appellant Marie Yammine, as former wife and primary beneficiary of a two million dollar life insurance policy issued by Respondent ReliaStar Life Insurance Company to her former husband, Dr. Jean Bernard, appealed a declaratory judgment finding the contingent beneficiary, Appellee Roland Ghoussoub, was entitled to the policy's death benefit. Dr. Bernard died after the trial court granted the parties' divorce but prior to final judgment on all issues. The trial court declared Yammine and Bernard were divorced and that 15 O.S.2011 § 178(A) operated to revoke her beneficiary designation to the death benefits. Whether Oklahoma's revocation-upon-divorce statute, 15 O.S.2011 § 178(A), applied when one party dies after the granting of the divorce but prior to final judgment on all issues, was a matter of first impression for the Oklahoma Supreme Court. The Court concluded Section 178(A) required a final judgment on all issues, and that the trial court erred by interpreting 15 O.S.2011 § 178(A) to revoke Yammine's beneficiary designation in Bernard's life insurance policy based on an order granting divorce when the final judgment on all issues remained pending at husband's death. The trial court's declaratory judgment was reversed, and this case was remanded for further proceedings. View "Ghoussoub v. Yammine" on Justia Law

Because the Louisiana Supreme Court found in its original opinion that plaintiffs had a right of action under La. C.C. arts. 2315.1 and 2315.2, their constitutional challenge was pretermitted and “that part of the district court judgment declaring [these code articles and La. C.C. art. 199 to be] unconstitutional as applied to children given in adoption” was vacated. Having found on rehearing that the codal analysis of La. C.C. arts. 2315.1, 2315.2 and 199 foreclosed a right of action to the plaintiff children, who were given in adoption, for the death of their biological parent and half-siblings, the Supreme Court was called on to address the propriety of the district court’s declaration that La. C.C. arts. 2315.1, 2315.2, and 199 are “unconstitutional as applied to children given in adoption.” The Court found a rational basis existed for limiting the categories of eligible claimants in La. C.C. arts. 2315.1 and 2315.2 to those who “are likely to be most affected by the death of the deceased.” Children given in adoption “have moved into a new parental relationship, becoming children ‘by adoption,’ who are eligible claimants in the unfortunate occurrence of the tortious death of their adoptive parents. Likewise, the transfer of children into a new parental unit as children ‘by adoption’ terminates, for purposes of wrongful death and survival actions, any connection between the ‘children given in adoption’ and any biological siblings who were not ‘given in adoption.’” For these reasons, the district court legally erred in finding that the fact that Daniel Goins and David Watts were adopted did not prevent them from bringing survival and wrongful death claims for the deaths of their biological father and biological half-siblings and in overruling the defendant’s exception raising the objection of no right of action. The Supreme Court's original decree was vacated and the district court's judgment was reversed. Judgment was entered sustaining the defendant insurance company's peremptory exception raising the objection of no right of action, and dismissing the claims that were the subject of this exception. View "Rismiller et al. v. Gemini Ins. Co." on Justia Law

Defendant Gemini Insurance Company appealed a district court's holding La. C.C. arts. 2315.1, 2315.2 and 199 were “unconstitutional as applied to children given in adoption” and overruling the defendants’ peremptory exceptions of no right of action. At issue was whether plaintiffs Daniel Goins and David Watts, two adult children who were given in adoption as minors, had a right to bring wrongful death and survival actions stemming from the deaths of their biological father and his two minor children, who were not given in adoption, and were plaintiffs’ biological half-siblings. After a de novo review, based on the clear and unambiguous wording of La. C.C. arts. 2315.1 and 2315.2, the Louisiana Supreme Court concluded Goins and Watts were “children of the deceased” and “brothers of the deceased” who were permitted to bring wrongful death and survival actions arising from the death of their biological father and half-siblings. In view of the Court's holding that plaintiffs had a right to assert survival and wrongful death actions, the Court declined to address their argument that La. C.C. arts. 2315.1, 2315.2 and 199 were unconstitutional as applied to children given in adoption. View "Rismiller v. Gemini Insurance Co." on Justia Law

The Supreme Court reversed the decision of the court of appeals applying a constructive trust to proceeds Lynnea Landsee-Pulkkila collected from a life insurance policy maintained by her late husband, James Pulkkila, holding that the court of appeals erred in imposing a constructive trust absent findings of fact that would support such an imposition.In 2009, James and Joan Pulkkila divorced. In their marital settlement agreement (MSA) that was incorporated into the judgment of divorce James and Joan were required to maintain life insurance with their children as beneficiaries. In 2013, James and Lynnea were married. The following year, James submitted a beneficiary name change asking that Lynnea be made the sole beneficiary of the life insurance policy. After Lynnea was paid the proceeds of the policy, Joan asserted that James breached the MSA agreement and that a constructive trust should be placed on the proceeds. The circuit court denied Joan's motion for a constructive trust. The court of appeals reversed, concluding that equity required the imposition of a constructive trust. The Supreme Court reversed, holding that the court of appeals erroneously exercised its discretion because it determined that a constructive trust was appropriate in the absence of an evidentiary hearing and resulting relevant factual findings. View "Pulkkila v. Pulkkila" on Justia Law