Schultz v. Schultz

591 N.W.2d 212, 1999 Iowa Sup. LEXIS 54, 1999 WL 160192
CourtSupreme Court of Iowa
DecidedMarch 24, 1999
Docket97-1391
StatusPublished
Cited by4 cases

This text of 591 N.W.2d 212 (Schultz v. Schultz) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schultz v. Schultz, 591 N.W.2d 212, 1999 Iowa Sup. LEXIS 54, 1999 WL 160192 (iowa 1999).

Opinion

TERNUS, Justice.

This case involves a dispute between a decedent’s widow and ex-wife over the proceeds of the decedent’s retirement account. The trial court found no basis to void the decedent’s designation of his former spouse as the beneficiary of this account, nor do we. Therefore, we affirm.

I. The facts of this case are undisputed. The decedent, Daniel Schultz, and the appel-lee, Paula Schultz, were married in 1970. In 1983, Daniel listed Paula as the beneficiary on his individual retirement account (IRA). Subsequently, in 1988, the couple’s marriage was dissolved. In the dissolution decree, Daniel was awarded the IRA as part of the court’s division of the parties’ property.

In 1990, Daniel married the appellant, Beverley Schultz. Five years later, Daniel died. Daniel had not changed the beneficiary designation on his IRA. Therefore, the proceeds of this account were paid to Paula as Daniel’s designated beneficiary.

Beverley was named the executor of Daniel’s estate. She filed this equity action individually and on behalf of the estate seeking a declaratory judgment that the plaintiffs were entitled to the proceeds of the retirement account because the dissolution decree had extinguished Paula’s rights as a beneficiary. Beverley sought to recover the proceeds of the IRA from Paula on the theory that Paula had been unjustly enriched by receiving benefits to which she was not legally entitled.

After a bench trial, the district court held that the dissolution decree did not address Paula’s status as a beneficiary of Daniel’s IRA, and therefore, did not terminate her expectancy interest in the account. Finding no basis in the evidence to void Daniel’s beneficiary designation, the court denied the plaintiffs’ request for damages and declaratory relief.

Beverley and the estate appealed. We review the ruling in this equity action de novo. See Hyler v. Garner, 548 N.W.2d 864, 870 (Iowa 1996); Iowa R.A.pp. P. 4.

II. The decedent had a written contract with the administrator of his retirement account that, in the event of his death, his account would be paid to Paula S. Schultz. Cf. In re Estate of Sheimo, 261 Iowa 775, 783, 156 N.W.2d 681, 685 (1968) (holding that designation of beneficiary made by owner of bank certificates of deposit constituted a contract with the bank); Prudential Ins. Co. v. Green, 231 Iowa 1371, 1374, 2 N.W.2d 765, 766-67 (1942) (“Life insurance, of course, is ordinarily a contract whereby, for a specified premium to be paid in various ways, the insurance company agrees to pay a stated sum to designated beneficiaries in the event of death of the insured while the contract is in force.”). The plaintiffs seek to alter this contractual obligation on the theory that the dissolution decree terminated any expectancy interest Paula had in Daniel’s IRA.

We note initially that Iowa follows the majority rule that “divorce or dissolution per se does not void the designation of a named spouse on a life insurance policy.” Sorensen v. Nelson, 342 N.W.2d 477, 479 (Iowa 1984). Beverley asserts that the rule should be different for retirement accounts because a retirement account has value during a decedent’s lifetime whereas a life insurance policy generally has little value until the decedent’s death. We do not think this distinction has any relevance, however, to the validity of a beneficiary designation, whether made with respect to a retirement account or an insurance policy. Therefore, we join other jurisdictions that apply the same rules to situations involving either the payment of life insurance proceeds or the payment of a retirement account to a decedent’s former spouse. See Johnson v. Johnson, 113 Idaho 602, 746 P.2d 1061, 1062 (Ct.App.1987) (holding characterization of IRA is not important; issue is whether ex-spouse “waived any rights as a beneficiary during the divorce proceedings”); Graves v. Summit Bank, 541 N.E.2d 974, 977 (Ind.Ct.App.1989) (stating that mere fact life insurance policies have no cash value as compared to retirement ac *214 counts does not justify applying different rules to these two assets); see also Estate of Bowden v. Aldridge, 595 A.2d 396, 397 (D.C.1991) (applying life insurance case law to retirement account dispute); Estate of Anello v. McQueen, 953 P.2d 1143, 1145 (Utah 1998) (same).

Accordingly, we start with a brief review of the Iowa cases wherein we have determined the effect of a dissolution on a former spouse’s right to recover the proceeds of the decedent’s life insurance policy as the designated beneficiary. In Lynch v. Bogenrief 237 N.W.2d 793 (Iowa 1976), we held that a spouse named as a beneficiary maintains that status even though subsequently divorced from the insured. 237 N.W.2d at 797. The divorce decree in Lynch made no mention of the death benefits payable by virtue of the decedent’s employment. Id. at 798. It merely provided that each party was to “have the title to and possession of their own personal belongings.” Id. We concluded the decree did not control the contingent interest of the ex-spouse in her former husband’s death benefits. Id. Therefore, we gave effect to the decedent’s designation of his ex-wife as the beneficiary of these benefits, despite testimony that the decedent disliked his former spouse and thought his death benefits would go to his second wife and minor children. Id. at 799.

In Sorensen, we noted the same general rule that a dissolution does not automatically void a beneficiary designation naming the former spouse. 342 N.W.2d at 479. We also observed, however, that a provision in a dissolution decree disposing of the policy proceeds would be given effect. Id. The dissolution decree at issue in Sorensen incorporated the parties’ stipulation. Id. at 478. The stipulation included a provision in which both parties “relinquish[ed] all rights of any kind not expressly provided for in this Agreement.” Id. at 478-79 (emphasis in original). We held that this language evidenced the parties’ intent to “wipe the slate clean,” including voiding the designation of the former spouse as the beneficiary on the decedent’s life insurance policy. Id. at 481.

More recently, we again considered whether a former spouse should receive the proceeds of two insurance policies on her ex-husband’s life in accordance with a pre-disso-lution beneficiary designation. In re Estate of Bickford,

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591 N.W.2d 212, 1999 Iowa Sup. LEXIS 54, 1999 WL 160192, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schultz-v-schultz-iowa-1999.