Metropolitan Life Insurance Company v. Johnson
United States Court of Appeals for the Seventh Circuit
297 F. 3d 558 (2002)
- Written by Sean Carroll, JD
Facts
Jimmie Johnson had a life-insurance plan through his employer, General Electric (GE), that was governed by the Employee Retirement Income Security Act of 1974 (ERISA). Jimmie designated his wife, Mildred Johnson, as the beneficiary of the plan. After the couple divorced, Jimmie filed a new beneficiary form, naming LaShanda Smith, Leonard Smith, and Carolyn Hall (defendants) as co-beneficiaries. Jimmie made several errors on this form, however, including checking the box for the wrong plan, writing a wrong address, and stating that he was separated from Mildred rather than divorced. Despite these errors, GE responded to Jimmie with a confirmation letter. Upon Jimmie’s death, GE informed Mildred that she was the beneficiary, but LaShanda Smith informed GE that Jimmie had changed beneficiaries after his divorce. Metropolitan Life Insurance Company (MetLife) (plaintiff), the insurance company that issued the plan, filed an interpleader action, asking the court to determine the proper beneficiary of the plan. The Illinois district court granted the Smiths and Hall summary judgment, finding that Jimmie substantially complied with the instructions of the change-of-beneficiary form. Mildred appealed.
Rule of Law
Issue
Holding and Reasoning (Manion, J.)
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