DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
131332P.pdf 05/08/2014 Jane Marie Hall v. Metropolitan Life Insurance
U.S. Court of Appeals Case No: 13-1332
U.S. District Court for the District of Minnesota - Minneapolis
[PUBLISHED] [Colloton, Author, with Riley, Chief Judge, and Kelly, Circuit
Judge]
Civil case - ERISA. The plan administrator reasonably determined that
Hall's decedent's will was inadequate to effect a change in beneficiary
for the life insurance policy in question as the estate was not the
beneficiary of the policy and the will did not address the distribution of
non-estate assets; a completed, but never filed, change of beneficiary
form was not sufficient to change beneficiaries under the provisions of
the plan since it was not submitted within 30 days of signature; assuming
for the sake of argument that the federal common law doctrine of
substantial compliance remains available, the doctrine does not compel a
different result, because where the ERISA plan administrator is given
discretion under the plan to determine eligibility for benefits, the
doctrine does not deprive the administrator from requiring strict
compliance with the terms of the plan.