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LIFE INSURANCE AND DIVORCE - Part 1
1999 National Legal Research Group, Inc.

Part One of Two

The issues that arise when a divorce court considers life insurance policies and benefits are many and varied. The recent case of Kearley v. Kearley, No. 97-05405 (Fla. Dist. Ct. App. Sept. 8, 1999), summarized the actions a divorce court can take with regard to life insurance policies and benefits as (1) treating the life insurance policy as an item of property to be classified, valued, and distributed; (2) treating the life insurance policy as a source of indemnity for unpaid obligations at the time of the obligor's death; and (3) treating the life insurance policy as a source of security to minimize future harm to the obligee in the event of the untimely death of the obligor:



Within the first category, i.e., division of the life insurance policy as a piece of property, the issues can be broken down further: Classification and valuation of the life insurance policy; The effect of a restraining order preventing a spouse from transferring property on the right to change the beneficiary; The effect of a divorce itself on a spouse's rights as a beneficiary; The effect of a decree or separation agreement awarding a life insurance policy to one spouse on the other spouse's beneficiary status; and The effect of a general waiver in a separation agreement whereby one spouse waives all rights flowing from the marital relationship on that spouse's rights as beneficiary.

Within the second and third categories, the issues can also be broken down further: The authority of a court to order a spouse to name the other spouse as beneficiary under a life insurance policy to secure a property division, alimony, or child support; The extent to which a former spouse is entitled to the proceeds under such an order; and The effect of the failure of a spouse to comply with such an order.

This issue of Equitable Distribution Journal will discuss the first set of issues, i.e., those relating to classification, valuation, and division of life insurance policies and proceeds.

A future issue will discuss the second set of issues, i.e., those relating to life insurance as security for other obligations. See generally Annotation, Divorce: Provision in Decree that One Party Obtain or Maintain Life Insurance for Benefit of Other Party or Child, 59 A.L.R.3d 152 (1974 & Supp. 1999).

Classification

As a general rule, a life insurance policy in existence at the time of classification of property is classified according to the general rules applicable to any other item of property: To the extent the premiums were paid with marital funds, the policy is marital property; to the extent the premiums were paid with separate property, the policy is separate property. Therefore, the policy itself can have both separate and marital components. E.g., Money v. Money, 852 P.2d 1158 (Alaska 1993); In re Ryman, 172 Ill. App. 3d 599, 527 N.E.2d 18 (1988); In re Marriage of Driscoll, 563 N.W.2d 640 (Iowa Ct. App. 1997); Wear v. Mizell, 263 Kan. 175, 946 P.2d 1363 (1997); Mount v. Mount, 59 Md. App. 538, 476 A.2d 1175 (1984); Reichert v. Reichert, 246 Neb. 31, 516 N.W.2d 600 (1994); Vail-Beserini v. Beserini, 237 A.D.2d 658, 654 N.Y.S.2d 471 (1997); Lindsey v. Lindsey, 342 Pa. Super. 72, 492 A.2d 396 (1985); Graham v. Graham, 195 W. Va. 343, 465 S.E.2d 614 (1995). But see La Barre v. La Barre, 251 A.D.2d 1008, 674 N.Y.S.2d 235 (1998) (life insurance was separate property where there was no evidence as to how many premiums were paid with marital funds).

Valuation

As a general rule, a life insurance policy in existence at the time of valuation of property is valued at its cash surrender value. Wisner v. Wisner, 129 Ariz. 333, 631 P.2d 115 (1981); In re Lorenz, 146 Cal. App. 3d 464, 194 Cal. Rptr. 237 (1983); In re Ryman, 172 Ill. App. 3d 599, 527 N.E.2d 18 (1988); Brown v. Brown, 519 N.E.2d 1259 (Ind. Ct. App. 1988); In re Marriage of Driscoll, 563 N.W.2d 640 (Iowa Ct. App. 1997); Leveck v. Leveck, 614 S.W.2d 710 (Ky. Ct. App. 1981); Kambur v. Kambur, 652 So. 2d 99 (La. Ct. App. 1995); Mount v. Mount, 59 Md. App. 538, 476 A.2d 1175 (1984); Neal v. Neal, 776 S.W.2d 861 (Mo. Ct. App. 1989); Dougherty v. Dougherty, ___ A.D.2d ___, 680 N.Y.S.2d 759 (1998); Dixon v. Dixon, 919 P.2d 28 (Okla. Ct. App. 1996); Toler v. Toler, 292 S.C. 374, 356 S.E.2d 429 (Ct. App. 1987); Caughan v. Caughan, 418 N.W.2d 791 (S.D. 1988); Grost v. Grost, 561 S.W.2d 223 (Tex. Civ. App. 1977).

See generally Annotation, Divorce and Separation: Method of Valuation of Life Insurance Policies in Connection with Trial Court's Division of Property, 54 A.L.R.4th 1203 (1987 & Supp. 1999). Of course, the court must subtract from the cash surrender value the principal amount of any outstanding loans against the policy. Ritter v. Ritter, 690 So. 2d 1372 (Fla. Dist. Ct. App. 1997). If a policy has no cash surrender value, then it has no value for purposes of property division. In re Footit, 903 P.2d 1209 (Colo. Ct. App. 1995); Davis v. Davis, 775 S.W.2d 942 (Ky. Ct. App. 1989); C.M.D. v. J.R.D., 710 S.W.2d 474 (Mo. Ct. App. 1986); Annis v. Annis, 189 A.D.2d 846, 592 N.Y.S.2d 786 (1993).

"Term life insurance" is a contract between the owner of the policy and the life insurance company whereby, in consideration for payments of premiums, the insurance company agrees to pay the beneficiary under the policy a specific amount of money if the insured dies during the term of the policy. Term life insurance has no cash surrender value or loan value. On the other hand, "whole life insurance" builds up equity in the insurance policy, and loans may be taken against it. 1 Eric Mills Holmes & Mark S. Rhodes, Holmes's Appleman on Insurance, 2d 1.25 at 126 (1996). Consequently, the conclusion can be drawn that term life insurance is not divisible, whereas whole life insurance is.

Even though term life insurance has no cash surrender value, at least one court determined that a term life insurance policy had economic value based on its replacement cost, its convertibility to whole life, and its face value. In re Marriage of Gonzalez, 168 Cal. App. 3d 1021, 214 Cal. Rptr. 634 (1985). The Gonzalez court analogized that term life insurance policies should be valued based on their replacement value, since replacement value may be higher than cash surrender value in situations where the insurability of the insured is lessened because of advancing age or declining health.

Distribution

When all or part of the life insurance policy is marital property, the owning spouse is generally awarded the life insurance policy, and the nonowning spouse is generally awarded cash or other property equal to his or her equitable share of the policy. In re Ryman, 172 Ill. App. 3d 599, 527 N.E.2d 18 (1988); Leveck v. Leveck, 614 S.W.2d 710 (Ky. Ct. App. 1981); Grost v. Grost, 561 S.W.2d 223 (Tex. Civ. App. 1977).

The Effect of a Restraining Order or Injunction on the Right to Change the Beneficiary

A number of states have statutes that automatically restrain a spouse from transferring marital or community property during the pendency of the divorce proceedings. E.g., Colo. Rev. Stat. 14-10-107(4)(b); 13 Del. Code 1509; 750 Ill. Comp. Stat. Ann. 5/501.1; Or. Rev. Stat. 107.105(1)(f). In some other states, a spouse may petition for such an injunction. E.g., Ariz. Rev. Stat. 25-315(A); Cal. Civ. Code 4359; Ga. Code Ann. 19-1-1; Ind. Code Ann. 31-1-11.5-7; N.J. Stat. Ann. 15-55-20(10); N.Y. Dom. Rel. Law 234; Va. Code Ann. 20-103; Wash. Code Ann. 26.08.110; (8) W. Va. Code 48-2-34. In all states, the court certainly has the equitable power to grant such an injunction.

If an injunction does not specifically prohibit a spouse from changing beneficiaries, e.g., Candler v. Donaldson, 272 F.2d 374, 376-77 (6th Cir. 1959) (order expressly directed insured to maintain all insurance policies during pendency of divorce; subsequent change of beneficiary therefore violated court order); Webb v. Webb, 375 Mich. 624, 134 N.W.2d 673 (1965) (enumerated within complaint and addressed in restraining order was prohibition from changing beneficiary on life insurance policy and retirement annuity contract); Hook v. Hook, 35 Ohio App. 3d 51, 519 N.E.2d 687 (1987) (ex parte temporary restraining order prohibited husband from changing beneficiary); Estate of Korzekwa v. Prudential Insurance Co. of America, 669 S.W.2d 775 (Tex. App. 1984) (temporary restraining order prevented husband from changing beneficiary designation on any life insurance policy); Standard Insurance Co. v. Schwalbe, 110 Wash. 2d 520, 755 P.2d 802 (1988) (preliminary injunction specifically ordered parties not to "change entitlements" on any insurance policies of either party); see also Edinburgh v. Massachusetts Mutual Life Insurance Co., 22 Mass. App.

Ct. 923, 492 N.E.2d 1182 (1986) (change of beneficiary by husband was accomplished before restraining order entered), there is a split in authority as to whether such general injunction prevents a spouse from changing beneficiaries during the pendency of the divorce.

The majority rule that has emerged is that where an injunction is couched in very general terms restraining a party from conveying or disposing of property, then a change in beneficiary is not a violation of the injunction for the simple reason that a change in beneficiary is not a transfer of property. The leading case stating this rule is Metropolitan Life Insurance Co. v. Tallent, 445 N.E.2d 990 (Ind. 1983). In that case, the restraining order prevented the parties from "`transferring, encumbering, and concealing or in any way disposing of any property except in the usual course of business or for the necessities of life.'" Id. at 991. The husband thereafter changed the beneficiary of his life insurance policy from his wife to his mother. One month later, during the divorce proceedings, the husband died. The husband did not violate the order, the court held, because the husband had not disposed of "property." The life insurance policy had no present value, payment of the proceeds was contingent on the husband's death, and there was no right to withdraw or receive benefits. Hence, the policy was not property, and a change in beneficiary could not be considered a violation of the restraining order. Many other cases have followed this reasoning. For example, in Lindsey v. Lindsey, 342 Pa. Super. 72, 492 A.2d 396 (1985), the court held that changes in beneficiaries on life insurance policies were not disposals of marital assets in violation of a preliminary injunction in a divorce action enjoining the husband from disposing of any marital property. The court reasoned that naming a beneficiary or changing a beneficiary is not a conveyance of an asset, and, therefore, the injunction did not act to restrain the husband from changing the beneficiary designation on two life insurance policies. Accord Pope v. Cauffman, 885 F. Supp. 1451 (D. Kan. 1995) (injunction that restrained each party from "selling, encumbering or disposing of the parties' property" did not prevent husband from changing beneficiary of life insurance policy); Succession of Jackson, 402 So. 2d 753, 756-57 (La. Ct. App. 1981) (injunction protecting community estate did not encompass right to change beneficiary); Gleed v. Noon, 415 Mass. 498, 614 N.E.2d 676, 677 (1993) (injunction which restrained the parties from "withdrawing, transferring, conveying, assigning, spending, encumbering, pledging, bequeathing or otherwise divesting themselves of any assets in which they have acquired an interest during their marriage to each other and which are subject to division" did not restrain husband from changing beneficiary of employee pension plan); Bishop v. Eckhard, 607 S.W.2d 716, 717-18 (Mo. Ct. App. 1980); Balfany v. Balfany, 239 Neb. 391, 476 N.W.2d 681 (1991) (order prohibiting parties from "concealing, encumbering, hypothecating, conveying or disposing of any property of the marriage" did not prevent husband from changing beneficiary from wife to father); Bell v. Bell, 896 S.W.2d 559, 564 (Tenn. Ct. App. 1994) (general injunction does not prevent change in beneficiary, as life insurance proceeds are mere expectancy, not property).

Some cases have disagreed and held that general restraining orders and injunctions, prohibiting a transfer of property and interests, are broad enough to include a change of beneficiary on a life insurance policy. See, e.g., Candler v. Donaldson, 272 F.2d 374 (6th Cir. 1959); Mack v. Allstate Life Insurance Co., 42 Ohio App. 3d 101, 536 N.E.2d 671 (1987).

The Effect of Divorce on Beneficiary Status

The general rule is that divorce does not, per se, affect or defeat a spouse's rights as a designated beneficiary in a policy on the other spouse's life, absent a change in beneficiary designation, a provision in the contract of insurance itself which makes the beneficiary ineligible if the status of spouse does not exist at the time of death, or a specific statute revoking beneficiary status on divorce. E.g., Jenkins v. Lovelady, 290 Ala. 25, 273 So. 2d 189 (1973); Cooper v. Muccitelli, 661 So. 2d 52 (Fla. Dist. Ct. App. 1995); Belote v. Belote, 167 Ga. App. 8, 306 S.E.2d 24 (1983); In re Estate of Downey, 293 Ill. App. 3d 234, 687 N.E.2d 339 (1997); Wolf v. Wolf, 147 Ind. App. 240, 259 N.E.2d 93 (1970); Hollaway v. Selvidge, 219 Kan. 345, 548 P.2d 835 (1976); Life Insurance Co. v. Jackson, 487 A.2d 1150 (Me. 1984); Redd v. Brooke, 96 Nev. 9, 604 P.2d 360 (1980); Harris v. Harris, 83 N.M. 441, 493 P.2d 407 (1972); Salvin v. Salvin, 165 A.D. 362, 151 N.Y.S. 60 (1914); Raack v. Bohinc, 17 Ohio App. 3d 15, 477 N.E.2d 1155 (1983); Rhodes v. Equitable Life Assurance Society, 109 Or. 586, 220 P. 736 (1923); Duncan v. Investors Diversified Services, Inc., 285 S.C. 467, 330 S.E.2d 295 (1985); Marquet v. Aetna Life Insurance Co., 128 Tenn. 213, 159 S.W. 733 (1913); Partin v. Cordova, 464 S.W.2d 956 (Tex. Civ. App. 1971); Estate of Anello v. McQueen, 953 P.2d 1143 (Utah 1998); Chase v. Chase, 74 Wash. 2d 253, 444 P.2d 145 (1968); Washington v. Hicks, 109 Wis. 2d 10, 325 N.W.2d 68 (Ct. App. 1982).

The rule is not universal, however. Some states have divestiture statutes whereby the status of a spouse as named beneficiary is terminated by the entry of the divorce decree, without regard to the fact that the spouse remains the named beneficiary. E.g., Mich. Comp. Laws Ann. 552.101; Tex. Fam. Code Ann. 3.632(a)-(c); Va. Code Ann. 20-111.1; Wash. Code Ann. 11.07.010.

The Effect of Distribution of the Policy Itself on the Right to Proceeds As Beneficiary

When a divorce decree awards a life insurance policy to one spouse as an item of property, the question arises as to whether the award to the one spouse divests the other spouse of rights as named beneficiary. See generally Annotation, Divorce Decree Purporting to Award Life Insurance to Husband as Terminating Wife-Beneficiary's Rights Notwithstanding Failure to Formally Change Beneficiary, 70 A.L.R.3d 348 (1976 & Supp. 1999).

Several courts considering this issue have held that a dissolution court's division of the parties' life insurance policies does not, by itself, affect a beneficiary interest; rather, some additional language addressing this expectancy interest is required or the beneficiary spouse must have waived this interest as part of a stipulation or settlement. Christensen v. Sabad, 773 P.2d 538, 540 (Colo. 1989) (en banc) (holding award of life insurance policy to decedent husband in dissolution proceeding did not extinguish ex-wife's expectancy as a beneficiary of the policy); In re Estate of Schleis, 97 N.M. 561, 642 P.2d 164, 165 (1982) (holding "divorce decree granting the insured spouse ownership of [life insurance] policies does not, by itself, sever the beneficiary interest of former spouse"); Lewis v. Lewis, 693 S.W.2d 672, 674 (Tex. App. 1985) (holding designation of wife as beneficiary not affected by divorce decree granting husband "any and all policies of life insurance"); Aetna Life Insurance Co. v. Wadsworth, 102 Wash. 2d 652, 689 P.2d 4 (1984) (division of community property does not work to divest spouse of beneficiary interest, which is not community property); Bersch v. VanKleeck, 112 Wis. 2d 594, 334 N.W.2d 114, 117 (1983) (holding divorce decree awarding insurance policies to husband dealt with ownership interest only and did not affect ex-wife's beneficiary interest).

On the other hand, some courts have held that a decree granting one spouse ownership of a life insurance policy terminates the other spouse's rights as beneficiary. Matter of Estate of Dobert, 192 Ariz. 248, 963 P.2d 327 (Ct. App. 1998) (wife had no expectation of benefits when divorce decree awarded husband his life insurance policy); Larsen v. Northwestern National Life Insurance Co., 463 N.W.2d 777 (Minn. Ct. App. 1990); Estate of Keeton v. Cherry, 728 S.W.2d 694 (Mo. Ct. App. 1987); McDonald v. McDonald, 632 S.W.2d 636 (Tex. App. 1982); Novotny v. Wittner, 731 S.W.2d 103 (Tex. App. 1987).

Effect of Distribution of Property in General or General Waiver of Right to Property of Other

A more difficult question arises when a property settlement agreement does not specifically assign the life insurance policy to one spouse, but instead the spouses waive all rights in the property of the other. Does this general waiver act to waive not only the property rights in the life insurance policy itself, but the beneficiary rights as well? Most courts allow a former spouse to waive beneficiary status by a separation agreement that specifically encompasses the proceeds. The waiver of survivor benefits or life insurance proceeds, however, must be specific:



4 Couch on Insurance 3d 64.19 at 64-35 (1996); accord 2 Stephen W. Schlissel et al., Separation Agreements and Marital Contracts 9A:07 at 126 (2d ed. 1997). See generally Annotation, Property Settlement Agreement as Affecting Divorced Spouse's Right to Recover as Named Beneficiary Under Former Spouse's Life Insurance Policy, 31 A.L.R.4th 59 (1984 & Supp. 1999). Consequently, a general waiver of rights will not affect a waiver of survivor benefits or life insurance proceeds; the waiver must be specific.



2 Alexander Lindey & Louis I. Parley, Lindey on Separation Agreements and Ante-nuptial Contracts 18.01 at 18-24 (2d ed. 1997). Various reasons have been put forth for this rule, but one consistent strain running through all the cases considering the scope of general waivers and beneficiary rights has been that beneficiary rights are a matter of contract law and do not flow from the marital relationship. Consequently, a general waiver of rights that arise out of the marital relationship cannot affect beneficiary status; a change of beneficiary must be accomplished by a contract that addresses those rights. E.g., National Auto Dealers & Associates Retirement Trust v. Arbeitman, 89 F.3d 496, 498 (8th Cir. 1996) (waiver of pension rights "arising out of the marital relationship" not sufficient to waive survivor benefits; wife's rights arose from beneficiary designation); Rountree v. Frazee, 282 Ala. 142, 209 So. 2d 424 (1968) (interest in life insurance policy does not arise from the marital relationship); Nunn v. Equitable Life Assurance Society, 272 N.W.2d 780 (N.D. 1978) (policy does not condition right to proceeds upon continuance of marriage and so does not arise out of marital relationship).

The leading case espousing this rule is Mullenax v. National Reserve Life Insurance Co., 29 Colo. App. 418, 485 P.2d 137 (1971). In this case, a Colorado Court of Appeals interpreted a separation agreement that did not specifically mention insurance and found that general language was not sufficient to terminate the beneficiary's rights.



485 P.2d at 139-40 (citation omitted); accord, e.g., Estate of Altobelli v. IBM Corp., 849 F. Supp. 1079 (D. Md. 1994) (applying Maryland law) (general release clause waiving claims and interests cannot waive beneficiary status because it is no more than mere expectancy); Manufacturers Life Insurance Co. v. Dougherty, 986 F. Supp. 928 (E.D. Pa. 1997) (applying Pennsylvania law); McClain v. Beder, 25 Ariz. App. 231, 542 P.2d 424 (1975); Cooper v. Muccitelli, 661 So. 2d 52 (Fla. Dist. Ct. App. 1995) (general release clause does not vitiate ex-spouse's beneficiary designation); In re Marriage of Velasquez, 295 Ill. App. 3d 350, 692 N.E.2d 841 (1998); In re Marriage of Myers, 257 Ill. App. 3d 560, 628 N.E.2d 1088 (1993); Lynch v. Bogenrief, 237 N.W.2d 793 (Iowa 1976); Hughes v. Scholl, 900 S.W.2d 606 (Ky. 1995); Standard Life Insurance Co. v. Franks, 278 So. 2d 112, 114 (La. 1973); Cassiday v. Cassiday, 256 Md. 5, 259 A.2d 299 (1969); Eschler v. Eschler, 257 Mont. 360, 849 P.2d 196 (1993); Ohran v. Sierra Health & Life Insurance Co., 111 Nev. 688, 895 P.2d 1321 (1995) (divorce decree must contain explicit language to divest former spouse of his or her rights as beneficiary); Redd v. Brooke, 96 Nev. 9, 604 P.2d 360, 361 (1980); Gerhard v. Travelers Insurance Co., 107 N.J. Super. 414, 258 A.2d 724 (Ch. Div. 1969); Raack v. Bohinc, 17 Ohio App. 3d 15, 477 N.E.2d 1155 (1983); Bruner v. Bruner, 864 P.2d 1289 (Okla. 1993); Prudential Insurance Co. v. Weatherford, 49 Or. App. 835, 621 P.2d 83 (1980); Girard v. Pardun, 318 N.W.2d 137 (S.D. 1982). See generally Note, Life Insurance Beneficiaries and Divorce, 65 Tex. L. Rev. 635, 637 (1987).

Some states, eschewing a bright-line rule, take a slightly different approach. In Kansas, for example, the court attempts to ascertain the parties' intent and will construe a settlement agreement or divorce decree to effectuate such intent, even though the insurance policy is not specifically mentioned. In Hollaway v. Selvidge, 219 Kan. 345, 548 P.2d 835 (1976), the Supreme Court of Kansas interpreted a property settlement agreement to include certain insurance policies even though the policies were not specifically mentioned. The agreement, which was approved by the court and incorporated into the divorce decree, referred to "all property rights and claims." The Kansas court stated the general rule that divorce does not affect a beneficiary designation and then discussed its interpretation of the exception to the rule:



548 P.2d at 839 (citation omitted).

The Kansas court also noted that the wife's interest in the policy was only an expectancy that could be divested by the husband's change of beneficiary, but it still found that the agreement included the insurance:



Id. at 840.

Because the focus of the inquiry is the intent of the parties, the courts have focused on a few major indicia of intent: Whether the policy owner had an opportunity to change the beneficiary designation but did not, whether there were any representations that the beneficiary status would not be changed, and whether the parties remained friendly after the divorce. E.g., Lincoln National Life Insurance Co. v. Blight, 399 F. Supp. 513 (E.D. Pa. 1975), aff'd, 538 F.2d 319 (3d Cir. 1976) (insured had ample opportunity to change beneficiary status but did not, and parties continued friendly relations after divorce; held wife's relinquishment of rights did not include beneficiary status of life insurance policies); Estate of Keeton v. Cherry, 728 S.W.2d 694 (Mo. Ct. App. 1987) (agreement, on the whole, evidenced intent of parties to release or revoke all of ex-wife's right to life insurance policies); Vasconi v. Guardian Life Insurance Co., 124 N.J. 338, 590 A.2d 1161 (1991) (property settlement agreement providing for mutual waivers of all claims or obligations raises presumption that beneficiary status was revoked; former wife would be entitled to proceeds if she could overcome presumption by evidence of parties' intent); Lelux v. Chernick, 119 Ohio St. 3d 6, 694 N.E.2d 471 (1997) (language of separation agreement was sufficient to eliminate husband and wife as beneficiary of the other, even without specific language, where their expression to waive all rights was unequivocal); DeVane v. Travelers Insurance Co., 8 N.C. App. 247, 174 S.E.2d 146 (1970) (insured's failure to formally change beneficiary left beneficiary rights intact, even though ex-spouse "relinquished rights" under policy); Nunn v. Equitable Life Assurance Society, 272 N.W.2d 780 (N.D. 1978) (where there was nothing in the transcript of the divorce proceedings to indicate the parties' intent to waive rights in insurance proceeds).

Because the courts look to the intent of the parties concerning policies existing at the time of the divorce, an ex-spouse will not be barred from taking the proceeds of a life insurance policy when the other ex-spouse took out the policy after the divorce was final. Raggio v. Richardson, 218 So. 2d 501 (Fla. Dist. Ct. App. 1969).

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