Hartford Life and Accident Insurance Company v. Valois

• Court: Court of Appeals for the Ninth Circuit
• Decided: November 5, 2024
• Docket: 23-3286
• Status: Unpublished

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS NOV 5 2024 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

HARTFORD LIFE AND ACCIDENT No. 23-3286 INSURANCE COMPANY, D.C. No. 3:21-cv-06469-RS Plaintiff,

v. MEMORANDUM*

MARILYNE VALOIS,

Defendant-Cross-Claimant - Appellant,

v.

HAILI KOWALSKI,

Defendant-Cross-Defendant - Appellee.

Appeal from the United States District Court for the Northern District of California Richard G. Seeborg, District Judge, Presiding

Argued and Submitted October 24, 2024 San Francisco, California

Before: OWENS, SUNG, and SANCHEZ, Circuit Judges.

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. Marilyne Valois appeals from the district court’s summary judgment in

favor of Haili Kowalski in this interpleader action concerning the proceeds of a life

insurance policy administered by the Hartford Life and Accident Insurance

Company (“Hartford Plan”). The district court held the Legal Separation

Agreement (“LSA”) between Kowalski and her deceased ex-husband was a

Qualified Domestic Relations Order (“QDRO”) under the Employee Retirement

Income Security Act of 1974 (“ERISA”). The LSA provides that the decedent

“shall carry and maintain a policy of life insurance in the amount of $800,000” and

“name [Kowalski’s minor son, E.K.] as sole beneficiary.” Thus, in accordance

with the LSA, the district court held E.K. had superior rights to the Hartford Plan

proceeds over the decedent’s girlfriend, Valois, who is the named beneficiary. We

review the district court’s interpretation of ERISA and summary judgment de

novo. Stewart v. Thorpe Holding Co. Profit Sharing Plan, 207 F.3d 1143, 1148

(9th Cir. 2000). We affirm.

1. Valois argues the LSA is not a QDRO because it does not clearly specify

the Hartford Plan. To be a QDRO under ERISA, a Domestic Relations Order

(“DRO”) must, among other requirements, “clearly specif[y]” “each plan to which

such order applies.” 29 U.S.C. § 1056(d)(3)(C)(iv). We require only “substantial

compliance” with ERISA’s specificity requirements. Hamilton v. Wash. State

Plumbing & Pipefitting Indus. Pension Plan, 433 F.3d 1091, 1097 (9th Cir. 2006)

2 23-3286 (citing Trs. of Dirs. Guild of Am.-Producer Pension Benefits Plans v. Tise, 234

F.3d 415, 420 (9th Cir. 2000)).

The LSA substantially complies with the specificity requirements. The

purpose of these requirements is to “spar[e] plan administrators the grief they

experience” due to “uncertainty concerning the identity of the beneficiary.”

Stewart, 207 F.3d at 1150 (emphasis and citation omitted). Here, there is no

uncertainty. Although the LSA only mentions “a policy of life insurance,” the

decedent had but one such policy—the one under the Hartford Plan. The LSA

clearly requires the decedent to name E.K. as the sole beneficiary on that policy.

Based on the unique facts of this case, where it is clear which plan is implicated,

the LSA substantially complies with ERISA’s specificity requirements and is a

QDRO. See Hamilton, 433 F.3d at 1097 (noting the “pivotal question” for

substantial compliance is whether the DRO “clearly contains the information

specified in the statute that a plan administrator would need to make an informed

decision” (quoting Stewart, 207 F.3d at 1154)).

2. Valois also argues the LSA is not a QDRO because it increases the

payment burden on the Hartford Plan. To be a QDRO, a DRO must not “require

the plan to provide increased benefits.” 29 U.S.C. § 1056(d)(3)(D)(ii). The

Hartford Plan proceeds totaled $493,000, which is less than the $800,000 policy

the decedent was obligated to maintain according to the LSA. However, the LSA

3 23-3286 is an agreement between the decedent and Kowalski, not between Kowalski and

Hartford. Nothing in the LSA requires Hartford to provide an amount greater than

$493,000. In fact, Hartford has deposited the proceeds and has been dismissed

from the underlying action. Moreover, Kowalski is not requesting more than is

allowed under the Hartford Plan. The LSA thus does not require the Hartford Plan

to provide increased benefits.

3. We affirm the district court’s grant of summary judgment. Each party

shall bear its own costs on appeal.

AFFIRMED.

4 23-3286