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11th Cir. – Life Insurance Ineligible Beneficiary

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  • 11th Cir. – Life Insurance Ineligible Beneficiary

    Here’s a new case out of the Eleventh Circuit titled David Glenn Morris v. Southern Intermodal Xpress, Assurant Employee Benefits, Union Security Insurance Company. This is a group term life policy issue offered by the plaintiff’s employer (SIX) and issued by Union. The policy offered dependent insurance which extended to eligible dependents, defined by the policy as a “lawful spouse”. The plaintiff was married at the time he became insured, but he divorced. Two months after his divorce, his ex-wife died. Plaintiff brought the present suit in an effort to obtain the life insurance benefits on his ex-wife.

    The court first found that the District Court did not err in liberally construing Morris’ complaint to raise a claim under § 1132(a)(1)(B). Second, the District Court did not err by dismissing the complaint against SIX, the plaintiff’s employer, for failure to state a claim. The court found that SIX was not liable under § 1132(a) because the complaint did not allege any impropriety on the employer’s part. Lastly, and most importantly, the court found that Union’s decision to deny benefits was correct.

    Here, we agree with the district court that Union’s decision to deny benefits was the correct one under the terms of Morris’s life-insurance policy. Morris’s policy provided coverage to “eligible dependent[s],” which included a “lawful spouse.” Coverage ended if a dependent was no longer “eligible.” It follows that, because Morris’s ex-wife was not his “lawful spouse” as of the date of their divorce, she ceased to be an “eligible” dependent as of that same date. See Killough v. Flowers, 843 So. 2d 770, 773 (Ala. Civ. App. 2002) (stating that “a trial court’s divorce judgment completely and finally dissolves the marital relationship between husband and wife on the date of its entry” (quotation marks omitted)). So, by the time of Morris’s ex-wife’s death nearly two months later, any dependent coverage had ended. Morris’s assertion that he is a “named beneficiary”—in the sense that he may have been entitled to benefits notwithstanding the divorce—finds no support in the language of the policy.
    The opinion is attached below.

    Attached Files
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