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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.