When an ERISA Beneficiary Change by Phone Call Fails: N.D. Alabama Enforces the Plan’s Written-Designation Requirement and Voids a Bigamous Marriage

In Metropolitan Life Insurance Company v. Williams, No. 4:24-cv-00357-CLM, 2026 WL 2569485 (N.D. Ala. Aug. 31, 2026), an ERISA interpleader case over a General Motors life insurance policy, District Judge Corey L. Maze held that a participant’s attempt to change his beneficiary by phone call failed under the plan’s written-designation requirement, and that the putative spouse who claimed the proceeds was never lawfully married to the participant. The court granted summary judgment to the participant’s three daughters and denied the competing motion filed by the estate of the woman listed on the policy. For anyone trying to understand how ERISA plans handle beneficiary disputes, the decision is a reminder that the plan document controls, and that courts read its designation procedures strictly.

Does a phone call change an ERISA beneficiary?

Not under this plan. Jan Ehemann participated in the General Motors Life and Disability Benefits Program, an ERISA-governed welfare benefit plan funded by MetLife. In a March 2020 phone call with a MetLife agent, Ehemann named Roslyn Smith as his beneficiary. After Ehemann died in 2023, MetLife declined to pay Smith because Ehemann’s three daughters from a prior marriage made a competing claim, and MetLife filed this interpleader action to let the court sort out the claims.

The court looked first to the plan text, applying the rule that the “cornerstone of an ERISA plan is the written instrument” and that administrators must manage plans in accordance with the governing documents. The beneficiary provision required a participant to make his choice “in writing on a form” approved by MetLife, with changes taking effect when “signed.” Nothing in that provision mentioned phone-call changes. The court held that Ehemann’s phone call therefore failed to designate Smith, because he never designated her in writing on a signed form.

Did the plan’s telephone “enrollment form” definition allow a phone designation?

No. Smith argued that the plan’s defined term “ENROLLMENT FORM,” which included “an election made through a telephone or other electronic enrollment system,” permitted a phone-call designation. The court rejected that reading. The enrollment-form definition governed enrolling in coverage, not the separate legal process of designating a beneficiary. The court also pointed to the plan’s use of defined terms: capitalized defined terms like “ENROLLMENT FORM” appeared in all caps throughout the policy, but the beneficiary provision used the lowercase, undefined phrase “in writing on a form.” Because that phrase was undefined, its ordinary meaning applied, and a phone call did not fall within the ordinary meaning of “in writing on a form.”

The court also turned aside Smith’s ERISA estoppel and substantial-compliance arguments. Estoppel did not apply because this was an interpleader between claimants, not a dispute between an insured and an insurer, so communications between MetLife and Ehemann were irrelevant. The court declined to apply the substantial-compliance doctrine because the Eleventh Circuit has never adopted it, and its viability is doubtful after the Supreme Court’s decision in Kennedy v. Plan Administrator for DuPont Savings & Investment Plan, which emphasized strict adherence to plan documents.

Who receives ERISA proceeds when there is no valid beneficiary?

The plan answered that question through its “No Beneficiary at Your Death” provision. With Smith’s designation invalid, the most recent written designation belonged to Ehemann’s prior wife, Sharon DeVarona, but her rights as beneficiary ended when she predeceased Ehemann. That left Ehemann without a valid designated beneficiary and triggered the fallback provision, which gave MetLife discretion to pay the estate or, in order, the participant’s surviving spouse, children, or parents.

Was the putative spouse actually a spouse under state law?

No, and this is where the opinion turned. Smith could take under the fallback provision only if she qualified as Ehemann’s “spouse.” The court applied state law to determine spousal status, noting that federal courts routinely rely on state law to identify a participant’s spouse in an ERISA plan, and rejecting Smith’s argument that ERISA preempted that inquiry. Because Smith and Ehemann married in Georgia, Georgia law governed the marriage’s validity.

Georgia law bars a person from marrying while still married to a living spouse. Smith had married Willie Smith in 1999, Willie did not die until 2021, and the record showed no divorce. Alabama court records reflected no divorce, Smith’s son testified he knew of no divorce proceedings, Willie’s 2021 obituary listed Smith as his wife, and Smith herself had signed a 2017 mortgage with Willie identifying them as “Husband and Wife” and referred to Willie as her husband on Facebook after marrying Ehemann. The daughters overcame the presumption favoring the second marriage, and Smith could not carry her shifted burden to show a divorce. Her marriage to Ehemann was therefore void, she was not Ehemann’s spouse, and the proceeds passed to Ehemann’s surviving children.

The court granted the daughters’ motion for summary judgment and denied the motion filed on behalf of Smith’s estate.