Engelman v. Connecticut General Life Insurance Company

In 1961, the decedent, Ella Ryder, obtained a life-insurance policy from Connecticut General Life Insurance Company (CGLI) (defendant). CGLI required that the policy owner seeking to change the policy beneficiary file “with the home office a written request therefore on a form satisfactory to the company and signed by the owner.” The change in beneficiary also had to be recorded by CGLI. Ryder named her husband as the policy beneficiary and her nephew as the contingent beneficiary. After her husband’s death, Ryder, as policy owner, could change the beneficiary. In 1977, Ryder asked her attorney, Robert Engelman (plaintiff), to change her estate plan. Ryder wrote to CGLI and asked CGLI to prepare and send a change-of-beneficiary form, making Ryder’s estate the beneficiary. CGLI never did. In 1979, Ryder sent a letter that she had signed, and Engelman had prepared and witnessed, changing her policy beneficiary. The letter included Ryder’s policy name and number. CGLI received the letter. Instead of recording the change, CGLI sent Ryder a change-of-beneficiary form and included a cover letter notifying Ryder that the policy would not be changed unless the form was dated, signed, witnessed, and returned to CGLI. Ryder never returned the form. Ryder paid her insurance premiums until she died. Engelman, who was the executor of Ryder’s estate, completed a CGLI claim form requesting that Ryder’s life-insurance policy proceeds be paid to him as executor. CGLI refused and formally denied Engelman’s claim, because, it maintained, Ryder had not requested the policy-beneficiary change on CGLI’s forms. Therefore, Ryder had not complied with CGLI’s beneficiary-change requirement. CGLI admitted that Ryder’s previous letter changing the policy beneficiary had complied with the formalities of CGLI’s requirement and that her intent was to change her policy beneficiary. Engelman sued CGLI, claiming that CGLI had violated state law and breached the life-insurance contract. The trial court entered judgment in favor of CGLI, finding that Ryder had not requested the beneficiary change on CGLI’s form.