- Amount
- $151,000 (fund awarded)
- Counsel
- Interpleader Law
- Result for
- The named beneficiary, the insured's former wife, our client
- Case
- Modern Woodmen of America v. Harris
- Court
- U.S. District Court, Northern District of Alabama
- Docket
- No. 7:26-cv-00239-EGL
- Decided
- August 20, 2026
- Issue
- Whether Ala. Code § 30-4-17 revokes a designation made before a divorce that predates the statute
The insured bought a $150,000 certificate from a fraternal benefit society in Alabama in 1999 and named his wife as beneficiary. They divorced in 2003. He never changed the designation, remarried, moved to Oklahoma and died there in 2025. His widow argued that the divorce had automatically cancelled the former wife’s designation. The insurer interpleaded the proceeds, and the widow also sued our client, the former wife, for fraud, abuse of process and related claims.
The court applied Alabama law because the certificate was applied for in Alabama. Alabama’s revocation-on-divorce statute, Ala. Code § 30-4-17, did not take effect until September 1, 2015, about twelve years after this divorce, and it has no retroactivity clause. Relying on the Alabama Supreme Court’s description of the statute as a “prospective default rule,” the court held that the 2003 divorce did not revoke the designation and declared the former wife entitled to the proceeds.
The court dismissed every crossclaim against our client with prejudice, noting that a party who answers a complaint naming her as a defendant “has done only what the federal rules require of her.” The insurer bore its own fees, so the fund passed to our client undiminished.
What it shows. Revocation-on-divorce statutes differ from state to state, and the date of the divorce can matter as much as the date of death.
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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