According to the Courthouse News Service, although Robert Alsager had signed a separation and property-settlement agreement with his ex-wife releasing claims to her estate or property, a three-judge panel of the 4th U.S. Circuit Court of Appeals said it leaned heavily on the 2009 decision for Kennedy v. Plan Administrator for DuPont Savings & Investment Plan, in which the U.S. Supreme Court concluded that a claim for benefits must stand or fall by the terms of the plan.
“We see no need and possess no warrant to unwind Kennedy and make a puzzle of plan administration … inasmuch as MetLife did what the law required it to do, the case against it must be dismissed and the judgment of the district court must be affirmed,” Wilkinson wrote, the news report said.
Courthouse News Service reports that Emma C. Boyd was an employee of Delta Airlines and participated in a life insurance plan administered by MetLife. When she joined the program, she designated her then-husband, Alsager, as the primary beneficiary of the plan, and designated her mother as the contingent beneficiary n the event that Alsager refused to take the benefits.
In spite of their separation and property-settlement agreement, Boyd never changed the beneficiary designation on file with MetLife. When she died in 2008, the Boyds filed a claim for the benefits from the life-insurance policy, as did Alsager, despite his having signed the settlement agreement.
Relying on the plan documents on file, MetLife determined that the benefits should be paid to Alsager and denied the Boyds’ claim. A lower court agreed this was correct.