Sveen v. Melin
United States Supreme Court
138 S. Ct. 1815 (2018)
- Written by Mary Katherine Cunningham, JD
Facts
Mark Sveen and Kaye Melin (defendant) married in 1997. During the marriage, Sveen purchased a life insurance policy naming Melin as the primary beneficiary and his children from a prior marriage, Ashley Sveen and Antone Sveen, as the contingent beneficiaries. Sveen and Melin divorced in 2007, and the divorce decree did not mention the life insurance policy. Sveen did not revise his beneficiary designations before his death in 2011. Ashley Sveen and Antone Sveen (plaintiffs) argued at trial in the district court that Minnesota’s revocation-on-divorce law cancelled Melin’s beneficiary designation. Melin countered that the Minnesota law did not exist when Mark bought the insurance policy and named her as the beneficiary. Melin argued that applying the later-enacted law to the policy would violate the Contracts Clause of the Constitution. The district court awarded the insurance money to the Sveen children, but the Eighth Circuit reversed, holding the Minnesota revocation-upon-divorce statute violates the Contracts Clause when applied retroactively. The Sveen children appealed.
Rule of Law
Issue
Holding and Reasoning (Kagan, J.)
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