Published by The Pellegrin Firm January 12, 2020

In a decision dated December 31, 2019, a federal district court in the Northern District of Texas found for the surviving spouse in a life insurance dispute between a deceased man’s spouse and his sons. The case is Miller v. Miller, No. 3:17-CV-2360-L, 2019 WL 7370433 (N.D. Tex. Dec. 31, 2019). Both the sons and the spouse submitted beneficiary designations purporting to be signed by the deceased. The insurance company decided it could not decide which beneficiary designation was valid. The insurance company initiated an interpleader action in federal court and deposited the policy proceeds in the registry of the court. Insurance companies will often take this course of action when they do not wish to risk paying out the policy proceeds to the wrong person and possibly becoming liable for paying out the policy proceeds twice.

After a brief bench trial, the district court found the deceased was suffering from dementia when both beneficiary forms were signed, and thus neither could be considered valid. The court therefore found the default beneficiary language in the policy should control, and that language dictated the money should go to the surviving spouse.