Court Found Decedent’s Expectations Were Consistent With Life Insurance Application


Decided December 2, 2015

This dispute focused on the beneficiary designations for life insurance policies.

Plaintiff Madeline Fromageot was the widow of decedent Paul Fromageot.  He died in 2004.  In 1996, the decedent completed an “enrollment card” which authorized his employer to deduct monies from his salary for premiums on a life insurance policy with Hartford Life Insurance Company (“Hartford”).  The policy provided a $452,500 death benefit.

The decedent listed four beneficiaries on the enrollment card for this policy:  plaintiff; defendants Henri and Juana Fromageot, who were his parents; and the eldest child of the decedent and plaintiff.

The enrollment card stated, “If more than one beneficiary is named, the death benefit, unless otherwise provided herein, will be paid in equal shares to the designated beneficiaries who survive the employee.” Similar statements were included in two other sections of the enrollment card, and in a booklet that described the terms of the policy.

The decedent later acquired another life insurance policy with a different company, with a death benefit of $2,000,000.  Plaintiff was the only beneficiary for that policy and received that sum on the decedent’s death.

After the procurement of these policies, plaintiff and the decedent had three additional children.

After the decedent died, Hartford contacted the four beneficiaries identified on the enrollment card.  Defendants received half of the death benefit, and plaintiff and the eldest child each received one-fourth of the benefit.

Plaintiff later filed litigation alleging that the decedent had always intended that she would receive the entire death benefit under the Hartford policy, should she survive him. She alleged that it was never his intention that fifty percent of the benefit be paid to defendants.

Plaintiff asserted a variety of claims, including misinterpretation, mistake of fact, unjust enrichment, and breach of fiduciary duties.

After hearing the trial, the judge concluded that the enrollment card stated unequivocally that if more than one beneficiary were listed, the benefit would be divided equally among the designated beneficiaries. The judge rejected plaintiff’s claims.  The judge further found that certain facts explained why the decedent designated defendants as beneficiaries under the policy:  the judge noted that the decedent and plaintiff had serious problems in their marriage.  The judge also cited the poor relationship between plaintiff and defendants while the decedent was alive.

The judge concluded that the decedent had not been misled by any ambiguity in the policy application when he listed his parents as beneficiaries, and found that it was reasonable to conclude that the decedent’s expectations were consistent with the plain language of the application.

Plaintiff appealed and raised a number of issues on appeal.

The Appellate Division affirmed the trial court and concluded that plaintiff’s arguments were without merit.