When a Phone Call Beats the Plan’s Writing Requirement: A Louisiana Court Applies Substantial Compliance to Uphold a Telephonic ERISA Beneficiary Change

In Adams v. Metropolitan Life Insurance Company, No. 24-668-SDD-RLB, 2026 WL 1662073 (M.D. La. June 9, 2026), the United States District Court for the Middle District of Louisiana, per Chief District Judge Shelly D. Dick, granted judgment on the administrative record to Metropolitan Life Insurance Company (“MetLife”) in an ERISA dispute over group life insurance benefits, holding that an insured substantially complied with the plan’s beneficiary-change requirements when she designated a new beneficiary by telephone, and that the disappointed claimant could not establish entitlement to the benefits in any event.

What Were the Facts Behind the Disputed Beneficiary Change?

The Insured obtained basic and optional life insurance through a group plan issued to her former employer, General Motors. Decades earlier, she had designated her parents as beneficiaries. In 2020, the Insured began living with Plaintiff, her daughter, due to health problems, and in 2021 Plaintiff hired a caregiver, Sefera Givens, to help care for the Insured. On August 16, 2022, Givens placed a call to the GM Benefits and Services Center with the Insured present. The recorded call captured the Insured giving permission for the representative to speak with Givens, personally affirming that she wanted Givens to receive 100% of the benefits, providing Givens’ information, and stating “I agree” to confirm the change by electronic signature. MetLife processed the change two days later. The Insured died on February 2, 2024, and MetLife paid Givens the full benefit. Plaintiff, contending she had been “scammed,” challenged the designation.

Did the Telephonic Change Comply With the ERISA Plan?

The court reviewed the claim de novo because the parties stipulated that MetLife lacked discretionary authority. Plaintiff argued the plan’s Certificate of Insurance required all beneficiary choices to be made “in writing on a form approved by” MetLife, and that the telephonic change therefore failed. The court agreed the Insured did not technically comply with the Certificate’s written-form requirement. The court declined to treat the Summary Plan Description’s reference to telephonic changes as controlling, noting that under CIGNA Corp. v. Amara, 563 U.S. 421 (2011), summary documents do not themselves supply the terms of the plan, and that both parties treated the Certificate as the operative contract.

How Did the Court Apply the Substantial Compliance Doctrine?

Despite the technical noncompliance, the court applied the federal common law doctrine of substantial compliance, under which an attempted beneficiary change is effective when the insured evidences intent to make the change and takes positive action substantially similar to what the plan requires. The court relied on the Fifth Circuit’s unpublished decision in Morgan v. Barrera, No. 21-20497, 2025 WL 1157549 (5th Cir. Apr. 21, 2025), and earlier authority including Hartford Life & Accident Insurance Co. v. Wilmore, 31 F. App’x 832 (5th Cir. 2002). The court found the Insured clearly evidenced her intent during the recorded call and undertook positive action by verbally affirming her choice and providing an electronic signature after the representative told her she could change her beneficiary by phone. The court noted, as Morgan did, that MetLife accepted and complied with the attempted change, weighing further in favor of honoring the Insured’s demonstrated intent. The court held the Insured substantially complied and that Givens became the beneficiary.

Could the Designation Be Set Aside for Undue Influence?

Plaintiff argued the designation should be invalidated because Givens unduly influenced the Insured. ERISA does not address undue influence in this context, and the court expressed reluctance to fashion federal common law on the question, particularly where Plaintiff conceded that Louisiana does not recognize undue influence claims for life insurance and instead pointed to Mississippi and Texas law. Assuming without deciding that such a claim was viable, the court found the record lacked sufficient factual support. Reviewing the recording, the court found the Insured recited her current address without difficulty, gave clear permission for Givens to speak, and personally verified her choice. The court concluded the recording could not supply sufficient support for an undue influence claim.

Why Couldn’t Plaintiff Establish She Was Entitled to the Benefits Anyway?

The court held that even if the designation of Givens were invalidated, the administrative record did not establish that Plaintiff was entitled to the benefits. MetLife’s records reflected that one of the Insured’s parents predeceased her but that the other remained living. Plaintiff sought to prove that parent had died in 2021 by attaching a death certificate to her brief and requesting judicial notice. Relying on Vega v. National Life Insurance Services, Inc., 188 F.3d 287 (5th Cir. 1999), the court held it was constrained to the evidence before the plan administrator and could not receive new evidence to resolve a disputed material fact. Because Plaintiff had stipulated to the completeness of the administrative record and the death certificate was not part of it, the court declined to take judicial notice, leaving Plaintiff unable to show she was the proper beneficiary.

Disposition

The court denied Plaintiff’s motion for judgment on the administrative record and granted MetLife’s motion, entering judgment for MetLife.