Life Insurance & Designated Beneficiary - Aderholt v. McDonald


Aderholt v. McDonald, [Ms. 1150878, Dec. 16, 2016] __ So.3d __ (Ala. 2016). The Supreme Court affirms a summary judgment entered by the Walker Circuit Court in favor of an ex-wife of a decedent, holding that she, rather than the decedent's mother, was entitled to the proceeds of a $150,000 life-insurance policy the decedent held at the time of his death because the ex-wife remained the designated beneficiary under the life insurance policy. The Court reiterates that "a divorce, by itself, has no impact on one spouse's status as the beneficiary of the other spouse's life-insurance policy." Ms. * 7-8, citing Flowers v. Flowers, 284 Ala. 230, 224 So.2d 590 (1969), and Kowalski v. Upchurch, 186 So.3d 460 (Ala. Civ. App. 2015). This legal principle "stems from the fact that any rights a beneficiary has to the proceeds of a life-insurance policy are contractual, not marital." Ms. * 9, citing Rountree v. Frazee, 282 Ala. 142, 209 So.2d 424 (1968). Here, because there is no evidence the decedent took any affirmative action indicating he did not want his ex-wife to be the beneficiary of the policy, the circuit court properly entered summary judgment in favor of the ex-wife as beneficiary under the policy.


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