Forfeiting Life Insurance Benefits

Dallas life insurance lawyers probably already know this case. It is a 1992, 5th Circuit opinion styled, Metropolitan Life Insurance Co. v. Teddy White v Leslie Yohey.
Leslie Yohey appeals an adverse summary judgment dismissing his claim for life insurance proceeds against Metropolitan.
Terri Yohey was the named insured under a group life insurance policy issued by Metropolitan under the Federal Employees Group Life Insurance Act (FEGLIA). At the time of her death she had not designated a beneficiary. Her widower, Leslie Yohey, was convicted of her murder.
Metropolitan brought this declaratory judgment action to determine the policy beneficiary. The district court held that under Texas law Leslie Yohey’s interest in the policy was forfeited because of the murder conviction. The court granted summary judgment in favor of Metropolitan and declared Terri Yohey’s father, Teddy O. White, to be the beneficiary. Leslie Yohey timely appealed.
Under both the policy and the FEGLIA, insurance proceeds are payable to an insured’s widow or widower in the absence of a designated beneficiary. The term widower is not defined by either the policy or the FEGLIA. This court has held, however, that in the absence of a policy or a FEGLIA definition, the term “widow” means “lawful widow” as defined by state law. Section 1103.151, Texas Insurance Code provides that “the interest of a beneficiary in a life insurance policy … shall be forfeited when the beneficiary is the principal or an accomplice in willfully bringing about the death of the insured.” The district court held, therefore, that Leslie Yohey’s claim to the life insurance was forfeited.
Yohey contends that Texas law cannot be used to disqualify him from a federal statutory right granted in the FEGLIA. He misperceives our holdings. In Spearman we held that the FEGLIA should be interpreted consistent with state terms defining domestic relations, citing the Supreme Court’s decision in De Sylva v. Ballentine. In applying the state definition of “children” to federal copyright law, the De Sylva Court explained:
The scope of a federal right is, of course, a federal question, but that does not mean that its content is not to be determined by state, rather than federal law. This is especially true where a statute deals with a familial relationship; there is no federal law of domestic relations, which is primarily a matter of state concern.
Our colleagues in the Seventh Circuit have held, for example, that the test for incorporation of a state law into the FEGLIA is determined by a balancing of the need for uniform national law to achieve a federal statutory purpose and the state’s interest in the resolution of a particular case. Applying this test, they then used state constructive trust principles to resolve a FEGLIA dispute.
Even if the homicide forfeiture rule were not the type of state domestic relations law that supplements the FEGLIA, that would not be dispositive herein, however, because the federal common law provides the same bar to recovery of life insurance proceeds by the murderer of the insured. We similarly dismiss Leslie Yohey’s alternative arguments urging the application of the laws of either New York or the District of Columbia; both jurisdictions provide that a conviction for killing the insured vitiates beneficiary status.
Leslie Yohey also maintains that his criminal trial was constitutionally infirm and that the district court erred in relying upon it for proof of his conviction. Yohey has exhausted his direct appeal; his conviction is final. The conviction alone triggers the forfeiture rule as a matter of state law and, in addition, is conclusive as a matter of federal law.
For the reasons assigned, the judgment of the district court is AFFIRMED.