State Farm Life Ins. Co. v. Avila

331 F. Supp. 3d 860
CourtDistrict Court, S.D. Iowa
DecidedJune 22, 2018
Docket4:17-cv-00366
StatusPublished
Cited by1 cases

This text of 331 F. Supp. 3d 860 (State Farm Life Ins. Co. v. Avila) is published on Counsel Stack Legal Research, covering District Court, S.D. Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Farm Life Ins. Co. v. Avila, 331 F. Supp. 3d 860 (S.D. Iowa 2018).

Opinion

IV. ANALYSIS

A. Effect of Decree and Change of Beneficiary

Two well-established propositions in Iowa law clarify the parties' rights in this case. First, under ordinary circumstances, a named beneficiary has no vested interest in the insurance policy. Stackhouse v. Russell , 447 N.W.2d 124, 125 (Iowa 1989) (citing Stolar v. Turner , 237 Iowa 593, 21 N.W.2d 544, 550 (1946) ). In other words, "the insured has complete control and domination of the policy" and may freely change beneficiaries. Stolar , 21 N.W.2d at 550 (quoting Potter v. Nw. Mut. L. Ins. , 216 Iowa 799, 247 N.W. 669, 671 (1933) ). The second proposition, however, is that when "the beneficiary is named pursuant to contract, the insured loses power to designate different beneficiaries." Stackhouse , 447 N.W.2d at 125 (citing Stolar , 21 N.W.2d at 550 (collecting cases) ).

Stackhouse establishes that this second proposition extends to dissolution decrees. Stackhouse , 447 N.W.2d at 125. In that case, the decedent obtained a life insurance policy during his first marriage. Id. After they divorced, the decree required the decedent to name his two children as the sole beneficiaries of the policy. Id. The decedent later remarried and named his second wife as the beneficiary, with his two children as contingent beneficiaries. Id. Upon his death, both his children and his second wife claimed the life insurance proceeds. Id. The court held decedent "could not avoid his obligation ... by changing beneficiaries of the policy," and thus, enforced the decree and ordered the life insurance proceeds paid to his two children. Id. at 126.

Like in Stackhouse , Ricardo obtained a life insurance policy during his marriage to *867Bobbi Jo. ECF No. 29-1 ¶ 1. After they divorced, the decree required Ricardo to name his children Elaina and Noah as irrevocable beneficiaries of "the Life Insurance policies currently insuring [his] own life." Id. ¶ 11. Like the decedent in Stackhouse , Ricardo subsequently attempted to change beneficiaries.4 ECF No. 30-1 ¶ 12. Applying the rule of Stackhouse , Ricardo was not able to change the named beneficiaries after the decree was entered.

Christina and Katherine contend that Stackhouse is distinguishable because, in that case, the decree addressed a specific insurance policy, whereas the decree in this case addressed any and all of Ricardo's life insurance policies at the time of the decree. ECF No. 32 at 2. Christina and Katherine do not, however, explain why this distinction is material and do not point to any authority that suggests it is. The Court finds no reason for this distinction to preclude Stackhouse 's applicability.

For the foregoing reasons, the Court concludes Ricardo's attempt to change the beneficiary to Christina is unenforceable. Therefore, Elaina and Noah have a superior claim to the disputed insurance proceeds.

B. Christina and Katherine's Additional Arguments

Christina and Katherine offer two additional arguments: (1) Elaina and Noah's claim is time-barred and (2) equity requires judgment in their favor. ECF Nos. 29 at 3-4, 32 at 2-3. The Court does not find either argument sufficiently persuasive to deny Elaina and Noah's motion.

1. Whether Elaina and Noah's Claim is Time-Barred

Christina and Katherine contend that Elaina and Noah's claim to the life insurance proceeds is time-barred. ECF No. 29 at 3 (citing Kan. Stat. Ann. § 59-2239 ); ECF No. 32 at 3 (same). The Court first notes this Kansas statute does not apply because this case is governed by Iowa law. But even if Kansas law applied, the facts of this case do not implicate this statute because section 59-2239 bars claims against a decedent's estate not filed within six months of the decedent's death. Kan. Stat. Ann. § 59-2239(1) ; see also Nelson v. Nelson , 288 Kan. 570, 205 P.3d 715, 730 (2009). The parties in this case are stating claims to life insurance proceeds not to assets in Ricardo's estate. Therefore, this case falls outside section 59-2239's scope. Accordingly, the Court concludes Elaina and Noah's claim is not time-barred as a matter of law.

2. Whether Equity Requires Judgment in Favor of Christina and Katherine

Christina and Katherine urge that equity requires judgment in their favor. ECF Nos. 29 at 4, 32 at 2-3. They point first to Ricardo's intent, arguing that "Christina Avila, Mr. Avila's daughter from a prior relationship, was an intended beneficiary of the life insurance policy in question at *868the time of the entry of the Decree." ECF No. 32 at 2-3.

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Bluebook (online)
331 F. Supp. 3d 860, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-farm-life-ins-co-v-avila-iasd-2018.