Vasconi v. Guardian Life Insurance Co. of America

Robert Vasconi was married to Leah (Vasconi) Wolf (plaintiff) from September 1982 until May 1985. In 1984 Robert designated Leah as beneficiary on his life-insurance policy with Guardian Life Insurance Company of America (Guardian) (defendant). Robert and Leah had a difficult relationship, with Robert’s father, Edgardo Vasconi (defendant), later stating that the animosity and hostility in their relationship caused Robert to develop severe alcoholism. Robert and Leah’s property-settlement agreement provided that each party would release any claims in the other’s estate. Robert died in 1986 from liver failure caused by alcoholism. Before his death, Robert did not change his life-insurance beneficiary, leaving Leah as the named beneficiary following Robert’s death. Edgardo, the administrator of Robert’s estate, claimed that Robert had intended to change the beneficiary but had been unable to perform the ministerial act because of his alcoholism, and that Leah had relinquished her right to the life-insurance proceeds in the property-settlement agreement. More than two years after Robert’s death, Leah filed a proof of claim seeking the life-insurance proceeds. Leah filed suit against Edgardo and Guardian seeking the proceeds. The trial court granted summary judgment in Leah’s favor, citing New Jersey precedent that the designated beneficiary of a life-insurance policy has a vested property right in the proceeds, and a beneficiary can only be changed in the manner provided by the insurance-policy contract. Guardian paid the proceeds to Leah, and the appellate court affirmed. Edgardo filed a petition for certification.