In Hall v. Met. Life Ins. Co., 750 F/3d 995 (8th Cir. 2014), the plaintiff’s husband participated in a life insurance plan, in which he named his son as beneficiary. After he married plaintiff, he executed a change of beneficiary form, but it was not filed until after he died. Shortly before his death, he executed a will that purported to designate plaintiff as beneficiary of the life benefit. Met Life denied plaintiff’s claim, and the court upheld the determination.
The court held that Met Life reasonably determined that the will did not change the beneficiary of the plan, because the benefit was not payable to the estate, and the will did not expressly address the distribution of assets that were not part of the estate. Though the court found that Met Life could have interpreted the will as effecting a change of beneficiary, but reasonably determined otherwise.
Nor did Met Life abuse its discretion by refusing to give effect to the unfiled change of beneficiary form. Plaintiff argued that she had substantially complied with plan procedures, and that substantial compliance was sufficient. The court noted that it was debatable whether the substantial compliance doctrine was valid law, but that, assuming it was, it did not change this result: “But that a court may decide as a matter of common law to excuse technical non-compliance with the terms of an ERISA plan does not mean that an administrator with discretion under an ERISA plan is forbidden to enforce strict compliance with plan requirements [emphasis by the court].”