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Life insurance proceeds if owner dies pendente lite

  • 1.  Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 12:37 PM
    Before I spend time and money researching...Im sure someone out there has the quick and easy answer to this one.  Husband lists his wife as beneficiary of his life insuracne policy.  Complaint for Divorce is filed, litigation is ongoing, and Husband dies, without ever changing the beneficiary.  Does wife get the proceeds since she is still listed by name as the beneficiary of his life insurance? Thanks again for the anticipated answers.

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    Andrew Economos Esq.
    Iselin NJ
    (609)655-8887

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  • 2.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 12:54 PM
    Hi, Andy:

    Yes, that's my understanding.

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    Robert Goldstein Esq.
    Manalapan NJ
    (732)972-1600

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  • 3.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 02:24 PM
    With the exception of the esteemed Mr. Goldstein, this message board is eerily silent.  I was hoping one of us would have come across this issue in the past.  Im getting conflicting info whether the wife will get the insurance proceeds or not.  Anyone else have any ideas? Thanks

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    Andrew Economos Esq.
    Iselin NJ
    (609)655-8887

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  • 4.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 02:39 PM
    I BELIEVE that once a Complaint has been filed, the spouse cannot inherit; BUT, I do NOT have a citation.

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    Paul Kostro
    726 West Saint Georges Avenue
    Linden NJ 07036
    (908)486-2200
    [email protected]
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  • 5.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 03:37 PM
    Paul:

    But that is different than a life insurance beneficiary, especially in NJ where the insured is not permitted to change beneficiaries without a court order.

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    Robert Goldstein Esq.
    Manalapan NJ
    (732)972-1600

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  • 6.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 04:20 PM
    The insurer has a contractual obligation to honor the beneficiary form.  If the deceased spouse changes the beneficiary designated on the Certification of Insurance to another person then the court could employ its arsensal of equitable remedies to retrieve funds.  Similarly, once a Complaint for Divorce is filed, and one party dies, the court can employ its equitable remedies. 

    "During pendency of divorce proceedings initiated by wife, estranged husband died and left entire estate to children by former marriage. The Superior Court, Chancery Division, Family Part, Middlesex County, determined that wife was not entitled to relief under equitable distribution statute nor was she entitled to elective share, but permitted wife to raise equitable claim and wife appealed. The Superior Court, Appellate Division, 229 N.J.Super. 370, 551 A.2d 989, affirmed. Estate of husband petitioned for certification, which was granted. The Supreme Court, Handler, J., held that: (1) wife was not entitled to equitable distribution of marital assets under divorce statute, as pending divorce was required, and husband's death had terminated divorce proceedings; (2) wife was not entitled to election under probate code, as she was excluded by virtue of living apart from husband during pendency of divorce proceeding at time of his death; and (3) nevertheless if warranted by evidence equitable remedy of constructive trust, utilizing principles of quasi-contract, could be invoked to provide for equitable distribution of marital assets to wife. "

    Carr v. Carr, 120 N.J. 336, 576 A.2d 872 (1990)
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    Barbara Cowen Esq.
    Hackensack NJ
    (201)525-0025

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  • 7.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 04:29 PM
    Thanks to many of you, today I have learned something, and I am very much indebted to you. Thank you. Paul.

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    Paul Kostro
    726 West Saint Georges Avenue
    Linden NJ 07036
    (908)486-2200
    [email protected]
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  • 8.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 02:51 PM
    A life insurance policy is a contract between the insurance company and the insured/owner of the policy.  The proceeds go to the designated beneficiary.  I had a case where a very old, forgotten, policy turned up when the insured died.  The beneficiary had never been changed.  The first wife received the proceeds by contract.

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    Nancy Gold Esq.
    Mount Laurel NJ
    (856)505-1700

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  • 9.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 02:55 PM

    Yes.  The designation of beneficiary is controlling.  Had they proceeded to a final divorce, however, I remember reading case law that said wife would not get it unless he reaffirmed designation post divorce.   I could be remembering that wrong.

    M
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    Marianne Auriemma Esq.
    Maywood NJ
    (201)712-9663

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  • 10.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 02:59 PM
    Andy:

    I may be more steamed than esteemed, but in any event, the general rule is that the named beneficiary gets the insurance proceeds. Read Prudential Insurance Co. v. Prashker which sets forth a good discussion of the law. Also, if you send me your email address, I can send you a copy of a brief I wrote on a recent appeal that was decided around early June (unpublished) in the case of Thomas v. Thomas. The issue in that case was different, however, in that the husband changed beneficiaries in contravention of the PSA, but the brief cites a lot of insurance cases in the divorce context.

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    Robert Goldstein Esq.
    Manalapan NJ
    (732)972-1600

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  • 11.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 04:15 PM
    I had this issue researched recently by an expert in estates and trust in NJ, who opined . . . exactly as Bobby has done.

    Upon divorce, the elective share right disappears.  But Will provisions and life insurance go where they say they should go.  Only the FJD changes that result, according to my colleague.  Was a shock to me, too.

    Hanan

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    Hanan Isaacs Esq.
    Kingston NJ
    (609)683-7400

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  • 12.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-02-2013 04:09 PM
    By the way, Marlene Browne emailed me the 2009 published decision in Hadfield v. Prudential, but that involved a situation where the actual divorce had occurred and there was a statute that specifically revoked a life insurance beneficiary designation after a divorce or annulment except where there was a court order compelling it, etc.

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    Robert Goldstein Esq.
    Manalapan NJ
    (732)972-1600

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  • 13.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-03-2013 10:56 AM
    There is no black or white answer, as you are now in the Carr v. Carr, 120 N.J. 336 (1990) "black Hole",
    i.e.,no jurisdiction for E.D. and no elective share.

    The Chancery Division, Family or Probate Part, is where an eguitable remedy will now be fashioned.
    I suggest you take a look at R.5:4-2(f) and Vasconi v. Guardian Life Ins. Co., 124 N.J. 338 (1991)
    (yea, I argued thecause for the Appellant) for some guidance. Good Luck.

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    Ronald M. Abramson Esq.
    Winne, Banta, Hetherington, Basralian & Kahn, PC
    Court Plaza South
    21 Main Street (East Wing)
    Hackensack NJ 07601
    (201)487-3800


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  • 14.  RE:Life insurance proceeds if owner dies pendente lite

    Posted 07-03-2013 04:03 PM
    You have been sucked into the Carr v. Carr, 120 N.J. 336 (1990) "black hole", i.e. no jurisdiction for E.D. and no statutory elective share. Your remedy is now equitable relief from either the Family Part or Probate Part of the Chancery Division. I suggest you take a look at R.5:4-2(f) and Vasconi v.Guardian Life Ins. Co., 120 N.J. 338 (1991) (yea, I argued for the appellant, successfully I might add), and infuse some of your own creativity. Good Luck.

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    Ronald Abramson Esq.
    Hackensack NJ
    (201)487-3800

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