- Amount
- $99,000 (death benefit awarded)
- Counsel
- Interpleader Law
- Result for
- The successor beneficiary, the insured's nephew, our client
- Case
- State Farm Life & Accident Assurance Co. v. Hobin
- Court
- U.S. District Court, Western District of New York
- Docket
- No. 1:22-cv-00611-LJV-LGF
- Decided
- February 27, 2024
- Issue
- Whether a separation agreement expressly preserved a former spouse's designation under EPTL 5-1.4
The insured named the woman he later married as primary beneficiary and his nephew as successor beneficiary. The couple divorced in 2021 under a separation agreement that did not require him to keep life insurance for her. He died two months later without changing the policy. The former wife and the nephew both claimed the benefit, and the insurer paid it into court.
We represented the nephew. New York’s Estates, Powers and Trusts Law § 5-1.4 revokes a former spouse’s revocable designation at divorce unless a governing instrument, such as the divorce judgment or a property agreement, expressly says otherwise. The former wife pointed to a clause about unpaid amounts owed under the agreement, but it covered only debts that were past due at death, and she showed none. Evidence of what the insured may have wanted could not override the statute’s automatic effect.
The court granted summary judgment for our client and directed the clerk to pay him the death benefit.
What it shows. In New York, a former spouse keeps a pre-divorce designation only if the divorce papers expressly preserve it or the insured names her again after the divorce.
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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