Hearing v. Minnesota Life Insurance Co.

793 F.3d 888 (2015)

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Hearing v. Minnesota Life Insurance Co.

United States Court of Appeals for the Eighth Circuit
793 F.3d 888 (2015)

  • Written by Sheryl McGrath, JD

Facts

Jon Holloway (Jon) divorced in 1998, and the divorce decree required him to have a life-insurance policy with proceeds payable to his children until his child-support duties were complete. One of his children was named Nikole; Jon called this child Nikki. Jon bought a life-insurance policy from by Minnesota Life Insurance Co. (Minnesota Life) (defendant). According to the terms of the policy, Jon could change the beneficiary only by submitting a signed, written request to the insurance company prior to his death. Jon designated the beneficiary as his sister, Joetta Hearing (Hearing) (plaintiff). Jon indicated that he wanted Hearing as the beneficiary so that Hearing could control the child-support payments after Jon’s death, rather than having Jon’s ex-wife control the child-support payments. Jon’s child-support duties were complete in 2008. Jon died seven years later, in 2013. At the time of Jon’s death, there was a note on or near his body addressed to Nikki. The note indicated that Nikki would receive all of Jon’s assets, and the note referenced the life-insurance policy number and the contact information for the insurance agent. Nikki submitted a claim to Minnesota Life for the insurance proceeds. Hearing also submitted a claim to Minnesota Life for the proceeds. In addition, Hearing filed a lawsuit against Minnesota Life for the proceeds. Minnesota Life filed an interpleader action, and as a result Nikki was included in the lawsuit. Hearing then moved for summary judgment. The district court granted summary judgment in favor of Hearing. Nikki appealed.

Rule of Law

Issue

Holding and Reasoning (Colloton, J.)

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