On September 15, 2010, the Sixth Circuit affirmed the summary judgments entered by the district court for the Western District of Tennessee (Memphis Division) in favor of Defendant and Third Party Appellee Metropolitan Life Insurance Co. ("MetLife") and Third Party Defendant-Appellee Dorothy Williams ("Dorothy") on a request for distribution of life insurance benefits under a Federal Employee Group Life Insurance policy issued by MetLife (the "Policy").
Decedent James Williams ("Mr. Williams") was employed by the U.S. Army Corps of Engineers and was covered by the Policy at the time of his death. In March 1995, Mr. Williams filled out a standard "Designation of Beneficiary" form (the "1995 Designation") designating his then-fianc?e Dorothy as the beneficiary under the Policy. Mr. Williams printed his name and signed his name in cursive in the specified places on the form, and he also checked the box indicating that the two-witness requirement had been met. Although the witnesses were not named as beneficiaries, the box stating that "Neither witness is named as a beneficiary" was left blank. Mr. Williams never married Dorothy, although she was listed as his wife on the form.
On July 20, 1996, Mr. Williams married Betty Williams ("Betty") and filled out another "Designation of Beneficiary" form (the "1996 Designation") naming Betty as the beneficiary. Two witnesses signed the form as "Witnesses to Signature" and Mr. Williams checked the box stating that he had signed in the presence of the two witnesses. He printed his name in the space requesting a printed name, but he left blank the box asking for "Signature of Insured."
Mr. Williams died on March 18, 20081 , at which time Policy proceeds of $280,000 became payable. The federal government forwarded the two beneficiary designations to MetLife, which received claims under the Policy from Dorothy and Betty. MetLife denied Betty's claim upon concluding that Mr. Williams did not sign the 1996 Designation and, therefore, did not meet the statutory requirements of FEGLIA. On September 15, 2008, Betty filed a declaratory action against MetLife seeking the Policy proceeds. Betty died on April 18, 2009, and Appellant Larry Bonner (administrator of Betty's estate) ("Bonner") was substituted as Plaintiff.
The district court denied Betty's summary judgment motion and granted MetLife's and Dorothy's respective summary judgment motions because "the handwritten name of the insured individual in a separate section does not satisfy the statute's requirements because the statute must be strictly construed and it requires a 'signature.'" Bonner appealed.
The Sixth Circuit affirmed. The Court noted that FEGLIA requires that a beneficiary designation must be "signed and witnessed," and that 5 C.F.R. § 870.802 further provides that a "designation of beneficiary must be in writing, signed by the insured individual, and witnessed and signed by 2 people."
In this case of first impression, the Sixth Circuit noted that it had not previously "encountered a situation where the signature line was left completely blank." The Court also acknowledged that "FEGLIA does not contain a provision defining the term 'signed.'" Bonner argued that the definition of signed should be taken from 1 U.S.C. § 1 and state law, which both look to an insured's intent when making a mark or writing. MetLife did not provide an alternate definition but instead claimed such definitions should not apply because an insured's intent is not open to examination under FEGLIA and interpretive case law.
While recognizing the statutory language and decisions from other courts, the Sixth Circuit found "a flaw in the reasoning of courts that have said only that the statute must be 'strictly construed,' and then moved quickly to conclude that such 'strict construction' requires finding that the form at issue in the case was not signed." Instead, the Court stated that Congress's addition of the word "signed" "does not necessarily mean that it has utterly forbidden inquiry into the maker's intent in evaluating what constitutes a 'signed' writing."
However, because the signature space on the 1996 Designation was "glaring[ly] left blank," the Sixth Circuit found that "no reasonable jury could conclude that Mr. Williams intended to sign the form designating his life insurance benefits to Betty." Mr. Williams had previously signed, in cursive, the 1995 Designation, and there was no other writing, printing, or other "'mark' on the 1996 Designation that could reasonably be construed to have been 'intended as' a signature by [Mr. Williams]." The Court further discounted Bonner's argument that the check mark in the box stating "I have signed this form in the presence of the two witnesses who have signed below" was indicative of the requisite intent. The Court found that fact was, at best, a showing that Mr. Williams "thought he had signed, but it cannot be construed as the 'mark' that [Mr. Williams] intended to be the very signature that he was asserting, by checking the box, that he had already applied somewhere else on the form." (emphasis original)
Finally, the Court considered the irregularities in the 1995 Designation naming Dorothy as beneficiary. These irregularities included the fact that Dorothy was named as Mr. Williams's wife (which she was not), that there were unchecked boxes on the 1995 Designation, and that the date was listed simply as "March." The Court, however, declined to ascribe any meaningful significance to those matters because none of them affected a statutory requirement under FEGLIA.
Accordingly, the Sixth Circuit affirmed the district court's grant of summary judgment because the decedent had failed to sign or otherwise place a mark in the signature block area on the 1996 Designation.
1 The Court's opinion states Mr. Williams died on March 18, 2009. This apparently is a typographical error.
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