Wood v. MartinAnnotate this Case
The Supreme Court affirmed the judgment of the circuit court awarding Tracey Martin her agreed-upon share of proceeds of John Wood's insurance policy after he committed suicide, holding that the circuit court did not err.
During their divorce proceeding, Wood agreed to maintain a preexisting life insurance policy for the partial benefit of Tracey Martin. The circuit court incorporated the agreement (the agreement) into the final divorce decree. Six years later, in defiance of the court order, Wood removed Martin as a beneficiary and designated his brothers, his new wife, and a friend as beneficiaries on the policy. Wood committed suicide two days later. In a lawsuit initiated by Martin, the insurer interpleaded the policy proceeds. The circuit court awarded Martin her share of the proceeds consistent with the divorce decree. The Supreme Court affirmed, holding (1) Va. Code 38.2-3122(B) did not bar Martin's claim because the final divorce decree that ratified and incorporated the agreement created an equitable assignment; and (2) faced with competing equities, the circuit court did not err in finding Martin's beneficial interest in the interpleader proceeds to be superior to that of the new beneficiaries.