Jackman Financial Corp. v. Humana Ins. Co.

Dist. Ct. did not err in granting defendant-insurance company's motion for summary judgment in ERISA action by plaintiff-assignee of insured's estate alleging that defendant wrongfully gave insurance proceeds under group policy to insured's children instead of insured's estate (under circumstances where beneficiary of policy had died simulataneously with insured), even though plaintiff had advised defendant of said assignment prior to defendant's award of insurance proceeds to children. Defendant's actions were not arbitrary where policy contained facility-of-payment clause that permitted defendant discretion to give proceeds of policy to insured's children, as well as insured's estate when named beneficiary was dead at time of insured's death. Moreover, administrator of estate did not have authority to assign any proceeds of policy prior to defendant's identification of estate as recipient under facility-of-payment clause. Fact that defendant had been aware of administrator's assignment was irrelevant.