Results · Interpleader · Beneficiary disputes

Named beneficiary receives $297,000; an open investigation was not evidence of a slaying

Contingent beneficiaries opposed payment because a police investigation of the insured's death remained open. The court held that without evidence, an open investigation does not disqualify a named beneficiary.

Amount
$297,000 (spouse rider benefit awarded to our client)
Counsel
Interpleader Law
Result for
The insured's wife, the named primary beneficiary, our client
Case
Primerica Life Insurance Co. v. Donley
Court
U.S. District Court, Northern District of Alabama
Docket
No. 3:18-cv-00995-AKK
Decided
October 18, 2019
Issue
Whether an unresolved police investigation, without evidence, triggers Alabama's slayer statute

The insured’s wife was the named primary beneficiary of a spouse rider on a life insurance policy. After the insured was killed, the insurer interpleaded the benefit. Contingent beneficiaries, minor children represented by a court-appointed guardian ad litem, opposed payment to the wife because a police investigation of the death remained open.

We represented the wife. Alabama’s slayer statute disqualifies a beneficiary who feloniously and intentionally killed the insured. Our client had not been arrested, charged or convicted, and the objection offered no evidence connecting her to the death. The court held that an open investigation alone is not evidence, granted our client’s motion, and entered final judgment directing the remaining benefit, with interest, paid to her.

What it shows. The party invoking a slayer statute must offer evidence. Suspicion and an unresolved investigation do not, by themselves, disqualify a named beneficiary.

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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