Federal Law And Texas State Forfeiture Statute

How does Federal law work with the Texas Slayer Statute, Texas Insurance Code, Section 1103.151?

This question is answered in the 1992, Fifth Circuit opinion styled, Metropolitan Life Insurance Co. v. White.

This is a summary judgement case.  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.

Under both the policy and FEGLIA, insurance proceeds are payable to an insured’s widow or widower in the absence of a designated beneficiary.    The Texas Insurance Code, Section 1103.151 provides that the interest of a beneficiary of 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.

Yohey contends that Texas law cannot be used to disqualify him from a federal statutory right granted in the FEGLIA.  This Court has held that FEGLIA should be interpreted consistent with state terms defining domestic relations.  In citing the U.S. Supreme Court, the Court stated “The scope of a federal right is, of course, a federal question, but that does not mean that its content is 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 common law of domestic relations, which is primarily a matter of state concern.”

The test for 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, the court uses 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 the life insurance proceeds by the murderer of the insured.

Yohey’s claims were dismissed by summary judgement.

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