Court Upholds MetLife’s Decision to Award ERISA Life Insurance Benefits to Long-Term Partner Over Parents

In a recent decision from the Northern District of Texas, the court affirmed MetLife’s determination that a decedent’s long-term partner—not his parents—was entitled to receive $350,000 in life insurance benefits under an ERISA-governed plan. The case, Metropolitan Life Insurance Company v. Wallace, et al., No. 3:24-CV-1520-X, 2025 WL 2986137 (N.D. Tex. Oct. 22, 2025), underscores the broad discretion ERISA plan administrators hold in interpreting plan terms and determining beneficiaries.

Background

Ambrose Bless, a long-time Wells Fargo employee, was covered under employer-sponsored life insurance and accidental death policies administered by MetLife. The plans were governed by the Employee Retirement Income Security Act of 1974 (ERISA).

Mr. Bless passed away without naming a specific beneficiary. Under the terms of the plan, if no beneficiary is designated, benefits are payable to the participant’s “Spouse or Domestic Partner” before any payment to parents.

At the time of his death, Mr. Bless was in a long-term, exclusive relationship with Jennifer Leigh Wallace. They had shared a home, maintained joint bank accounts, and Mr. Bless had listed Wallace as the beneficiary for other Wells Fargo benefits.

After his death, Wallace submitted a claim to MetLife as his Domestic Partner. Mr. Bless’s parents, Michael and Patricia Bless, also filed a competing claim. Following an investigation, MetLife determined that Wallace met the plan’s definition of “Domestic Partner” and denied the parents’ claim.

MetLife then filed an interpleader action to resolve the competing claims and deposited the $350,000 into the court’s registry.

The Court’s Analysis

Judge Brantley Starr granted summary judgment in Wallace’s favor, finding that MetLife acted within its discretion under the plan’s terms and that its decision was supported by the evidence.

Deference to Plan Administrator

Under ERISA, plan administrators must follow plan documents when making benefit determinations, and courts review such decisions under an “abuse of discretion” standard when the plan grants discretionary authority. A decision is upheld so long as it is not “arbitrary or capricious.”

The court noted that MetLife’s conclusion—that Wallace qualified as Mr. Bless’s Domestic Partner—was based on substantial evidence, including shared residence, joint finances, and long-term mutual dependence. These facts satisfied the plan’s detailed definition of a domestic partnership.

The court rejected the parents’ arguments that MetLife acted improperly or failed to make a determination, explaining that the record clearly showed MetLife had evaluated Wallace’s claim and denied the parents’ appeal on that basis.

State Law Marriage Proceedings Irrelevant

The parents also argued that ongoing state probate proceedings, in which Wallace had been found to be Mr. Bless’s common-law wife, should affect the ERISA determination. The federal court disagreed, emphasizing that ERISA plan benefits are governed by the plan’s own terms, not by state probate law.

Even if the state appellate court later reversed the finding of a common-law marriage, MetLife’s determination under the ERISA plan would remain valid because it was made independently under the plan’s criteria for “Domestic Partner.”

The Court’s Holding

Finding no genuine disputes of material fact, the court held that:

• MetLife did not abuse its discretion in determining that Wallace was Mr. Bless’s Domestic Partner;
• Wallace is entitled to the $350,000 in life insurance and accidental death benefits; and
• MetLife properly denied the parents’ competing claims.

The court also clarified that its order did not address any claims involving other Wells Fargo benefits under separate plans.

Key Takeaways

• ERISA plan administrators have broad discretion when determining beneficiaries, and their decisions will be upheld if reasonable and supported by the record.
• Plan terms—not state court rulings—control the distribution of ERISA benefits. Even a common-law marriage finding under state law does not override a plan’s definition of “Domestic Partner.”