Results · Interpleader · Beneficiary disputes

Fifth Circuit reverses judgment against a widow whose federal beneficiary form was lost

The trial court held that a beneficiary form missing from the employee's file needed proof of receipt by the agency. The Fifth Circuit reversed, holding that hand delivery can be proved by witness testimony.

Amount
$418,000 (court-ordered payment to our client after remand)
Counsel
Interpleader Law
Result for
The insured's widow, our client
Case
Metropolitan Life Insurance Co. v. Vasquez
Court
U.S. Court of Appeals for the Fifth Circuit, on appeal from the U.S. District Court, Northern District of Texas
Docket
5th Cir. No. 24-11024; N.D. Tex. No. 4:24-cv-00009-BJ
Decided
October 1, 2025
Issue
When a federal life insurance beneficiary form counts as "received" by the employing office under 5 U.S.C. § 8705(a)

A federal employee named his mother as beneficiary of his Federal Employees’ Group Life Insurance. Years later, after he married and before deploying overseas, he signed and had witnessed a new form naming his wife. His supervisor said he watched the employee hand the form to the human resources officer on duty. After the employee died, the agency could not find the newer form, and the program’s administrator found the mother’s claim valid. The insurer filed an interpleader, and the trial court entered judgment for the mother, holding that a form missing from the personnel file needed some sign that the office had received it.

We represented the widow on appeal. In an unpublished decision, the Fifth Circuit reversed. The statute pays the beneficiary designated in a signed and witnessed writing received in the employing office before death. The court held that “received” does not require a stamp or a copy in the personnel file, and that a form is received when the employee hands it to an appropriate person at the employing office. Receipt can be shown by witness testimony, and attacks on the supervisor’s memory were credibility questions for trial. The court sent the case back for trial. The case later settled, with $418,000 paid to our client under the district court’s order.

What it shows. A lost federal beneficiary form is not necessarily a dead one. A claimant who can prove delivery, including through a witness, can get to trial even when the agency has no copy.

Read the court's order

For a detailed legal summary of this decision, see interpleader.com's decisions library.

Past results do not guarantee a similar outcome. This summary describes the court's ruling; it is not legal advice about any other case.

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