Eighth Circuit: ERISA Plan Beneficiary Designation Trumps Will

The Eighth Circuit held that the named beneficiary of an ERISA governed life insurance policy was entitled to the proceeds even though the decedent's will named a different beneficiary. Hall v. Metro. Life Ins. Co., 2014 U.S. App. LEXIS 8652 (8th Cir. May 8, 2014). Dennis Hall, the decedent, obtained a life insurance policy issued by MetLife and named his son, Dennis Hall II, as the sole beneficiary. Hall subsequently married Jane Hall but never added her as a beneficiary of the life insurance plan. Although he completed and signed a beneficiary-designation form naming Jane as the sole beneficiary, he never submitted the form to MetLife. After being informed that he had little time to live, Hall executed a will stating that all life insurance and benefits should be distributed to Jane Marie Hall. Hall died shortly thereafter.