Engle v. Land O'Lakes, Inc., No. 18-2821 (8th Cir. 2019)
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The decedent had insurance policies with Unum Life. After he died, he was survived by two minor children and his domestic partner. The district court granted a declaratory judgment, holding that Unum Life had adopted an unreasonable interpretation of the plans to support its decision to pay the domestic partner rather than the decedent's estate.
The Eighth Circuit reversed, holding that Unum life reasonably interpreted the plan as allowing it to pay a decedent's domestic partner in the absence of a designated beneficiary. In this case, it was reasonable for Unum Life to interpret the word "spouse" in the plan to include domestic partners and to pay the death benefits to the covered person's domestic partner. Accordingly, the court remanded with instructions to enter judgment in defendant's favor.
Court Description: Arnold, Author, with Smith, Chief Judge, and Kelly, Circuit Judge] Civil case - ERISA. It was reasonable for the plan administrator to interpret the word "spouse" in the plan to include domestic partners and to pay the death benefits to the covered person's domestic partner.
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