Hearing v. Holloway, No. 14-2819 (8th Cir. 2015)
Annotate this CaseIn 1998, as required by his divorce decree, Jon purchased a $100,000 life insurance policy from Minnesota Life. Although the decree required Jon to maintain a life insurance policy payable to his children until his child support obligations ended, Jon designated his sister, Joetta, as beneficiary. His child support obligations ended in 2008. Jon died in 2013. On or near his body was found a handwritten note purportedly signed by Jon and expressing his intent that his daughter, Nikole, receive the proceeds of the life insurance policy. Joetta sought an order directing the insurer to pay the proceeds to her. Minnesota Life moved to interplead the funds and to join in the action. Nikole filed a counterclaim, seeking an order directing Minnesota Life to pay the proceeds to her. The district court granted Joetta summary judgment. The Eighth Circuit affirmed, reasoning that Jon did not take adequate steps to change the beneficiary from Joetta to Nikole under the policy’s change-of-beneficiary requirements and Nikole presented no evidence that Joetta agreed to give the proceeds to Nikole, or that Jon asked Joetta to do so
Court Description: Colloton, Author, with Murphy and Kelly, Circuit Judges] Civil case - Insurance. In a dispute over whether the insured had taken adequate steps to change the beneficiary of his life insurance policy, the district court did not err in finding that the insured had not filed a written request with the insurer to change the beneficiary and that a handwritten note found near his body at the time of his death was, under Iowa law, an expression of unexecuted intent to make a change insufficient to comply with the notice requirements of the policy; defendant was not entitled to a constructive trust over the policy proceeds as she failed to show that plaintiff obtained her beneficiary status through any wrongdoing; defendant had adequate notice the district court would treat plaintiff's motion to dismiss as a motion for summary judgment.
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