Benefit Form Governs Despite Intent of Participant

September 26, 2005 ( - The US 6th Circuit Court of Appeals reversed a lower court's ruling and decided that a deceased participant's husband was due her employer-provided life insurance proceeds though it was clear she intended to change her beneficiary designation.

According to the court opinion, the lower court had made its ruling based on recorded phone conversations between Patricia Hardy-Craig and her employer’s benefits plan administrator which obviously showed that Hardy-Craig wished to change her beneficiary designation from her husband to her three daughters.  

The appellate court ruled that the plan was governed by ERISA which says that the plan is to be administered according to the “documents and instruments governing the plan.”   Therefore, since the beneficiary designation form on file at the time of Hardy-Craig’s death named her husband as beneficiary, he was entitled to the insurance proceeds.

In January 1999, when the policy became effective, Hardy-Craig designated her three daughters as beneficiaries.   In May 1999, when she married, she sent a beneficiary designation form to the plan administrator changing her beneficiary to her husband.   This was the form on file at the time of her death in 2000.

The phone conversations clearly showed that Hardy-Craig did not want her husband to be beneficiary and wanted to name her three daughters, but the change process was delayed due to Hardy-Craig not knowing her PIN and then not timely receiving the forms.   The administrator did not receive a signed change form from her before her death.

The full text of the opinion is  here .