Results · Interpleader · Beneficiary disputes

Mother awarded $332,000 in ERISA life benefits over an estate's community-property claim

A surviving spouse, as estate administrator, claimed the benefit because community funds paid the premiums. The court held ERISA and the plan controlled and awarded the benefit to the named beneficiary.

Amount
$332,000 (ERISA group life benefit awarded to our client)
Counsel
Interpleader Law
Result for
The insured's mother, the named beneficiary, our client
Case
Sun Life Assurance Co. of Canada v. Estate of Wheeler
Court
U.S. District Court, Western District of Washington
Docket
No. 2:19-cv-00364-JLR
Decided
January 28, 2020
Issue
Whether a community-property claim defeats the named beneficiary of an ERISA group life plan

An employee covered by his employer’s group term life plan, governed by ERISA, named his mother as beneficiary. After he died, his spouse, acting as administrator of his estate, wrote to the employer and the insurer contesting the mother’s right to the benefit on the ground that community funds had paid for the coverage. The insurer interpleaded the benefit.

We represented the mother. The estate waived service but never appeared, and its default was entered. Even so, the court addressed the merits. It found that the estate’s letters gave the insurer a reasonable fear of double liability, which justified interpleader, and that our client’s claim rested on her status as the sole named beneficiary, which ERISA and the plan both supported. Because ERISA preempts Washington’s community property laws, the estate had no claim to the proceeds. The court entered default judgment for our client and ordered the benefit, with interest, paid to her.

What it shows. For an ERISA plan, the plan documents and the named beneficiary control. A spouse’s community-property theory does not override them.

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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