Phoenix Mutual Life Insurance Company v. William Jackson Adams, Iv, Rosita L. Adams

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• recognizing that a participant’s failure to change the beneficiary under the plan is a situation different from determining' the beneficiary’s entitlement to benefits, and allowing the doctrine of substantial compliance in that unique situation
• recognizing the Court was “creating new, albeit limited, federal common law” and that the Court would “limit [its] holding to the facts” of the case
• holding that doctrine of substantial compliance is preempted
• applying the doctrine of substantial compliance to determine whether an'ERISA life insurance policy holder has changed the beneficiary of her plan, even though the plan provides for a very specific procedure to make such a modification
• finding substantial compliance where insured had left “change beneficiary to” line blank but thereafter instructed person in charge of making such changes to make the change, and through inadvertence of finance department employee the change was not effectuated prior to insured’s death
• “ERISA is silent on the matter of which party shall be deemed beneficiary among disputing claimants.”

Source: CourtListener parenthetical corpus (CC0).