Intent Is Not Enough: Kentucky Federal Court Holds ERISA Life Insurance Benefits Go to Named Beneficiary Absent Substantial Compliance With a Change

In Unum Life Insurance Co. of America v. Crane, No. 5:24-CV-00230-MAS, 2026 WL 1706791 (E.D. Ky. June 12, 2026), United States Magistrate Judge Matthew A. Stinnett granted summary judgment to the named beneficiary of an ERISA-governed group life insurance policy, holding that a decedent’s repeated statements of intent to remove that beneficiary did not effect a change where he never took action to carry the intent out. The decision is a clear application of the substantial-compliance doctrine to a contested beneficiary designation under an ERISA plan, and it underscores how much weight the written designation carries when the record shows intent but no completed change.

What did the ERISA plan and the beneficiary designation look like?

Crane worked for Challenge Manufacturing Holdings, Inc., which offered employees a group health and welfare plan governed by ERISA and funded through a group policy issued by Unum. As part of his initial enrollment, Crane designated Carta, with whom he later began a romantic relationship, as the beneficiary of his life insurance. At the time of his death he carried $46,000 in basic coverage and $100,000 in voluntary coverage. Employees managed their benefits through an ADP Workforce portal, where they could view and change elections, with changes routed to the employer’s human resources team for approval during open enrollment or a qualifying life event.

Did the decedent ever change his beneficiary?

No. The relationship deteriorated in late 2022, and Crane’s life insurance became a point of friction. In November 2022 Crane told Carta he had met with the employer’s HR staff, and the texts between them suggested he intended to remove her as beneficiary. He accessed his benefits portal that month, but the action showed as “pending,” and the employer’s former HR director testified that Challenge had no way of knowing what, if any, change Crane contemplated because he never submitted anything. In December 2022 Crane texted that he would “fix” his life insurance policies the next day to “erase this mistake,” language acknowledging he had not yet made any change. In April 2023 Crane again accessed the portal and increased his coverage, but he did not remove Carta. Crane died on August 3, 2023, survived by two sons. Carta remained the named beneficiary, and Unum filed an interpleader after receiving competing claims.

What standard governed the dispute?

The court applied ERISA’s framework, under which claims touching the designation of a beneficiary fall within ERISA’s broad preemptive reach and are governed by federal law. ERISA and its surrounding federal common law begin from the position that a named beneficiary receives the benefits even against expressions of intent to the contrary, subject to an exception for substantial compliance. Finding no established federal common law in the circuit on the question, the court drew guidance from Kentucky law, under which substantial compliance is met where the insured “had done all he could do under the circumstances” to effect the change.

Why did the decedent’s sons lose despite evidence of his intent?

The court held that the surviving sons could not satisfy the burden of substantial compliance. The critical facts were undisputed: Crane knowingly designated Carta, accessed the portal in November 2022 without submitting any change, texted his intent to remove her in November and December 2022 while taking no action to do so, and increased his coverage in April 2023 without removing her. The court reasoned that nobody could say what Crane did when he accessed the portal, and it would not construct substantial compliance on assumptions. Crane’s December text was, in the court’s words, “fatal,” because he would only say he was going to make the change if he knew he had not already made it. The court rejected the sons’ reliance on a prior federal decision involving Carta, finding the facts distinguishable and Carta’s credibility not at issue, because none of the critical facts came from her. Quoting circuit precedent, the court concluded that no matter how much evidence showed what Crane intended, “one glaring fact remains: He did not do it.”

The court granted Carta’s motion for summary judgment, denied the sons’ motion, and directed that the interpleaded funds held in the court’s registry be paid in accordance with the judgment.