District Court Awards ERISA-Governed Life Insurance Proceeds To Decedent’s Girlfriend, Rejecting Son’s Claim of Fraud or Duress In Change of Beneficiary

In Metropolitan Life Insurance Company v. Muecke, et al., No. CV 22-01029, 2023 WL 7131041 (W.D. La. Oct. 30, 2023), Louisiana Western District Judge Donald E. Walter granted Defendant-in-Interpleader’s Motion for Summary Judgment and awarded to Decedent’s girlfriend the life insurance proceeds deposited by MetLife with the Court.

Decedent was an employee of the National Railway Carriers and United Transportation Union who participated in the union’s employee welfare benefit plan. Decedent passed away on August 14, 2021, after which life insurance benefits under the Plan became payable. Decedent’s former girlfriend was designated as the Decedent’s sole beneficiary under the Plan, and she submitted a claim to MetLife to recover benefits. Decedent’s son contested the beneficiary designation alleging fraud, coercion and/or undue influence, and submitted a competing claim. With such competing claims, MetLife filed the instant interpleader action and deposited the funds with the Court.

On cross-motions for summary judgment, Decedent’s girlfriend attached the beneficiary designation form to her motion and argued that she was the sole beneficiary. Decedent’s son argued: (1) that the Court should disregard the designation as it was not produced until ordered by the Magistrate Judge in the pretrial conference; (2) that the girlfriend unduly influenced Decedent in making the designation; (3) that the signature on the form was not Decedent’s; and (4) that Decedent was traveling on the day the form was purportedly signed and could not have provided his signature.

The Court first noted that the beneficiary designation form was not improperly withheld, as Decedent’s girlfriend had not been in possession of the form until the time it was produced as ordered by the Magistrate Judge. The Court found that Decedent’s son had failed to show “a misrepresentation or a suppression of the truth with the intention either to obtain an unjust advantage” or “cause a loss or convenience.” Decedent’s son offered no specific statements (with identification of the speaker, date, and location) he contended to be fraudulent. That Decedent was purportedly traveling by car on the date the form was executed further did not demonstrate fraud. That Decedent’s signature included his full middle name, when Decedent’s son argued that his father only signed using his middle initial, was not evidence of fraud. Finally, an affidavit from Decedent’s daughter claiming that her father had told her that Decedent’s son was the sole beneficiary of the life insurance proceeds, and that his girlfriend’s name was “not on anything” was inadmissible hearsay and did not fall under the dying declaration exception as the statement was not made while the declarant believed his death to be imminent. The Court ordered the life insurance proceeds awarded to Decedent’s girlfriend and MetLife’s attorneys’ fees to by paid from the interpleaded funds.

If your insurer has denied or terminated any insured employee welfare benefits, contact us for assistance.