DaimlerChrysler Corp. Healthcare Benefits Plan v. Durden

In 1966, Douglas Durden married Ann Linzy (defendant) in Ohio. Douglas and Ann lived together in Ohio until 1982, when Ann left Douglas and moved to Tennessee. Douglas and Ann had two children together in Ohio. In 1975, Douglas had a child with Rita Marshall (defendant) in Ohio. Douglas and Rita married in Nevada in 1985. Douglas wrote on the marriage certificate that his marriage to Ann had been terminated in Tennessee in 1971. However, Ann denied divorcing Douglas, and Tennessee court records revealed no relevant divorce decree. Douglas and Rita lived as husband and wife in Ohio until Douglas’s 2003 death. Douglas was employed by DaimlerChrysler Corporation (Daimler) in Michigan and participated in Daimler’s Healthcare Benefits Plan (plan) (plaintiff). The plan was governed by Michigan law and provided for death benefits to Douglas’s surviving spouse. Douglas also was covered by a Daimler insurance policy, which provided for surviving-spouse benefits. After Ann and Rita both sought recognition as Douglas’s surviving spouse in federal court in Michigan, Daimler filed an interpleader complaint seeking a determination as to who should receive Douglas’s benefits. Rita argued that Michigan law governed the dispute per the plan and that Michigan law presumed the validity of a later ceremonial marriage that was challenged due to a claim that one spouse was still married. Ann argued that Ohio law governed due to Ohio’s stronger interest in determining who was Douglas’s surviving spouse. Ann noted that Ohio had expressly rejected Michigan’s approach to marriage validity, instead presuming that a prior marriage was valid. After concluding that Michigan law applied, the trial court granted summary judgment to Rita. Ann appealed.