Florinda Lynch moved to Summary judgment as pro se Crusade Royal Martin, Jr. objected. In Metropolitan Life Insurance Company v. Florinda Lynch, et al ., No. CV-19-08056-PCT-JJT, U.S. District Court of Arizona (March 23, 2021), the USDC was asked to determine who had entitlement to earned funds when the insurer could not determine who was entitled to death benefits due to the need to apply the law of the Navajo Nation. , Jr. Both claim that they are the legitimate benefits of a life insurance benefit from the Interpleader Plaintiff Metropolitan Life Insurance Company ("MetLife") in the amount of $ 135,869.86 resulting from the death of Royal Martin, Sr. Interpleader MetLife deposited the disputed funds with the court.
Decedent was employed by Navajo Nation and a participant in the Navajo Nation Benefit Plan issued by MetLife, which included a group life insurance policy. The plan enabled participants to nominate beneficiaries, and on June 21, 1995, Decedent appointed Martin, Jr., his son, the sole beneficiary to plan benefits through an employee employment form. On May 4, 1999, Decedent completed an application for coverage coverage where Lynch was the sole beneficiary to plan benefits and identified her as a "make-up team". At his death in 2017, the death certificate in New Mexico stated that Decedent remained married to Naomi Platero; they married in 1983 and later separated but they never divorced.
After Decedent's death, Lynch filed a claim for the plan benefits and identified himself as Decedent's "former spouse." Upon request, she informed MetLife that she and Decedent were married and had separated, but since it was a public marriage, there was no divorce decree. Because Arizona law provides that a divorce usually revokes a recipient's deed of marriage, but neither a marriage certificate nor a divorce decree exists to formalize the relationship between Decedent and Lynch, MetLife filed with this interpreter to resolve the issue of Lynch or Martin, Jr. is entitled to the plan benefits.
This dispute concerns the validity of Lynch's appointment as a plan recipient at Decedent's death. The decedent lived in Arizona at the time of planning and his death and Arizona law governs the plan. Both Decedent and Lynch expressly agreed to marry under joint law with MetLife, and Lynch has also sued.
The Navajo Nation, where Decedent lived, allows public marriage and Arizona generally recognizes and gives effect to Navajo Nation law.
Navajo Nation law only allows contracts for marriage between unmarried people, so if Decedent was still married to Platero, he could not have been married to Lynch. But it is clear that Decedent and Lynch kept getting married according to Navajo Nation law. Decedent is explicitly stated as such in the coverage update. Decedent and Lynch sought recognition and benefits of joint marriage law under Navajo Nation law, which Arizona law recognizes, including in the forms associated with MetLife plan benefits.
Under Arizona law, a divorce revokes a life insurance policyholder's designation to the former spouse. As Lynch valued the termination of the common law marriage between her and Decedent, MetLife questioned the validity of Lynch's appointment as beneficiary at the time of Decedent's death.
At that time, he entered into a joint marriage with Lynch and so stated on If Decedent was not still legally married to Platero and the joint law marriage was valid, the court must find that the end of the marriage with Lynch revoked the recipient designation to Lynch. The language of this charter indicates the clear intention that the life insurance benefits for the spouse end at the end of the marriage. Lynch can now not claim that he is not divorced from Decedent just to receive the plan benefits.
If Decedent was still legally married to Platero at the time he submitted the coverage update, it was a material misrepresentation in Lynch as his common law. breach of the terms of the coverage update itself, which requires truthful information and warns that "errors or omissions may result in loss of coverage and unpaid claims." According to all marital relationships, marital status is significant with respect to the distribution of marital assets. In addition, it would accept a claim that a valid divorce from a previous marriage occurred when it would not validate a subsequent bigamous marriage between a participant therein. In such a case, the court must and concluded that the coverage update was invalid and could not be enforced.
Since the designation of the beneficiary of Lynch could not be enforced in any of the scenarios, the Court concluded that it must give effect to the earlier appointment of the recipient. at the time of Decedent's death, namely to Decedent's son, Martin, Jr. and they were convicted in favor of Royal Martin, Jr., who appears pro se in this matter and is under the minutes and Royal Martin, Jr., is entitled to $ 135,869.86, representing death benefits due of a life insurance policy for Royal Martin, Sr., issued by the Metropolitan Life Insurance Company and deposited with the court on August 6, 2019 (Doc 22) plus any accrued interest. The court clerk must immediately send the funds identified above in the amount of $ 135,869.86 plus any accrued interest to Royal Martin, Jr. according to the judgment of the Court.
It is axiomatic that where there is a will, there are relatives. In the same way, where there is life insurance, there are relatives who seek the benefits. The USDC, in a Solomon-like decision, concluded that the common law marriages entered into by the accused, although permitted by the Navajo Nation and Arizona supporting Navajo law, were invalid and only the former beneficiary could receive the benefits due to the misrepresentation of the reverse when he tried to change the recipient to his common spouse.
© 2021 – Barry Zalma
Barry Zalma, Esq., CFE, now limits his practice to acting as an insurance consultant specializing in insurance coverage, handling insurance claims, fraud and insurance fraud almost
and for insurance companies alike. policyholder. He also acts as an arbitrator or mediator for insurance-related disputes. He practiced law in California for more than 44 years as an insurance coverage and claims lawyer and more than 52 years in the insurance business. He is available at http://www.zalma.com and firstname.lastname@example.org.
Mr. Zalma is the first recipient of the first annual Claims Magazine / ACE Legend Award.
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