Jackson v. Smith
Texas Court of Appeals
703 S.W.2d 791 (1985)
Sylvester Jackson and Eliza Smith (defendant) lived together as husband and wife for five years. During this five-year period, Sylvester obtained a life-insurance policy and identified his sister, Betty Jackson, as the policy’s beneficiary. The life-insurance policy premiums were paid for with community-property funds belonging to Sylvester and Eliza. When Sylvester died, Betty claimed the insurance proceeds and argued that the gift was reasonable because she was Sylvester’s sister and she was providing for his children from a previous marriage. Betty received other property from Sylvester as a gift, including $60,000 in life-insurance proceeds from a separate policy. Betty did not submit evidence to the court about whether these gifts were reasonable in proportion to Sylvester and Eliza’s total community estate. Eliza objected and argued that Sylvester had committed fraud on the community by naming Betty as the beneficiary instead of Eliza. The insurance company (plaintiff) filed an interpleader action against Betty and Eliza to determine who was entitled to the life-insurance proceeds. The trial court determined that fraud on the community existed and awarded half the life-insurance proceeds to Eliza and half to Sylvester’s estate. Betty appealed.
Rule of Law
Holding and Reasoning (Allen, J.)
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