ERISA And Life Insurance

ERISA lawyers should read the opinion 2016, opinion from the Houston Division, Southern District of Texas. The case is styled, Margaret Myklebust v. McDermott, Inc., et al.
Plaintiff sued MetLife seeking a declaration that she is entitled to recover life insurance benefits attributable to the decedent, John Drayton, as his surviving spouse.
A Motion For Summary Judgment was filed and the Court ruled in favor of Plaintiff. In rendering its decision the court discussed the facts of the case.
This case arises out of competing claims for insurance benefits between two women, each of whom claims to be the “lawful” surviving spouse of Drayton. The plaintiff and Tallet have filed a Joint Statement of Facts stipulating to the following undisputed facts:
John D. Drayton (the “decedent”) died on January 1, 2012, in Singapore, Republic of Singapore.
The decedent was employed by a McDermott affiliated company on July 17, 2007, and remained an employee until his death.
The decedent and the plaintiff were married on July 25, 2002, in Winnsboro, Fairfield County, South Carolina.
The decedent fraudulently obtained an Agreed Final Decree of Divorce in Cause No. 2006-03166 (the “divorce proceeding”) in the 245th Judicial District Court of Harris County, Texas dated October 18, 2006.
The decedent and Tallet participated in a marriage ceremony on July 2, 2007, in Harris County, Texas.
After July 2, 2007, on at least two occasions, the decedent represented to McDermott that Tallet was his spouse.
A Judgment Granting Bill of Review, dated September 14, 2012, was issued in the divorce proceeding holding the decedent’s Agreed Final Decree of Divorce void.
The divorce proceeding was dismissed by an Order dated September 14, 2012.
As an employee of a McDermott affiliated company, the decedent was a participant in the McDermott Thrift Plan and maintained life insurance benefits payable under the Group Insurance Plan for Employees of McDermott, Incorporated and Participating Subsidiary and Affiliated Companies (the “Life Insurance Plan”).
The Life Insurance Plan is governed by ERISA. MetLife is the claims administrator of the Life Insurance Plan and issuer of the group policy that funds the benefits.
Following the decedent’s death, both the plaintiff and Tallet made claims, as surviving spouse, to the McDermott Thrift Plan benefits attributable to the decedent as well as to the Life Insurance Plan benefits payable by reason of the decedent’s death.
Kathleen Nimmo, McDermott’s custodian of records, testified: “If John D. Drayton had made a beneficiary designation under any McDermott benefit plan in which he was a participant, the designation should be contained in his employment file.”
The decedent’s employment file was examined and did not contain a beneficiary
designation for either the McDermott Thrift Plan or the Life Insurance Plan.
McDermott has no beneficiary designation in its possession relative to the McDermott Thrift Plan benefits that are the subject of this suit.
McDermott has no application form, enrollment form, renewal form, or beneficiary designation form in its possession relative to the McDermott Life Insurance Plan benefits, which are the subject of this suit.
After a trial on the merits, an Heirship Judgment was issued in Cause No. 410,987, In Re: Estate of John D. Drayton, Deceased by Probate Court No. 3 of Harris County, Texas naming the plaintiff as the decedent’s lawful spouse, their daughter, Liv Jewel Drayton, as his minor child, and Tallet, as the decedent’s putative spouse.
The thrift plan benefits are described in the McDermott Thrift Plan.
The Life Insurance Plan benefits are described in two documents: (1) the McDermott Investments, LLC Benefit Plan Certificate -” Your Benefit Plan”; and (2) the Life Insurance Benefit Summary Plan Description.
The following additional facts are drawn from the uncontested evidence contained in the
record now before this Court:
On October 11, 2012, the plaintiff filed the instant declaratory judgment action against
McDermott and MetLife seeking to collect Thrift Plan benefits and Life Insurance Plan benefits as the decedent’s lawful surviving spouse.
Tallet, the decedent’s putative spouse as declared by the Judgment Declaring Heirship
issued by Harris County Probate Court No. 3, filed an unopposed motion to intervene
in this action on December 13, 2012.
On December 17, 2012, this Court entered an Order granting Tallet’s motion to intervene.
Shortly thereafter, Tallet filed claims in interpleader against MetLife and McDermott.
On January 30, 2013, MetLife filed a motion to deposit the Life Insurance Plan benefits, in the amount of $300,000, plus applicable interest, into the registry of the Court and for dismissal of it and McDermott with prejudice, arguing that it is unable to determine the respective rights of the plaintiff and Tallet under the Life Insurance and Thrift Plans and faces multiple liability in the event it pays the wrong party. It also sought dismissal of Tallet’s claims in interpleader.
Subsequently, this Court, entered an Order granting MetLife’s motion to deposit funds, motion for discharge and motion to dismiss Tallet’s claims in interpleader.
On or about March 6, 2013, MetLife deposited $301,660.27, the proceeds of the Life
Insurance Plan, into the registry of the Court.
This Court then cited the plan language and applied that language to the facts in the case and ruled in favor of Myklebust.