Sun Life Assurance Co. v. Jackson, No. 17-3120 (6th Cir. 2017)Annotate this Case
Bruce and Bridget married in 1993. Their only child, Sierra, was born in 1995. In 2003, Bruce signed up for a life insurance plan sponsored by his employer and governed by the Employee Retirement Income Security Act (ERISA). Bruce listed his uncle as the sole beneficiary. Bruce and Bridget divorced in 2006. Bruce died in 2013, insured for $48,000 in basic life insurance and $191,000 in optional life insurance. In their 2006 divorce decree, Bruce and Bridget agreed to maintain any employer-related life insurance policies for the benefit of Sierra until she turned 18 or graduated from high school. Bruce had not changed his beneficiary. The district court ordered payment to Sierra. The Sixth Circuit affirmed. The divorce decree suffices as a qualified domestic relations order that, incorporating the Jacksons’ separation agreement and their shared parenting plan, “clearly specifies” Sierra as the beneficiary under 29 U.S.C. 1056(d)(3)(C). Her parents’ (alleged) non-compliance with the decree does not limit Sierra’s rights under ERISA.