Kutrubis v. Kamberos

Federal 7th Circuit Court
Civil Court
Life Insurance Change of Beneficiary
Citation
Case Number: 
No. 24-3277
Decision Date: 
July 29, 2026
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Affirmed.
Judge: 
LEE

Plaintiff instituted an interpleader action to determine the correct beneficiary of life insurance proceeds when the decedent tried to change the beneficiary shortly before his death but where the insurance company did not receive the change of beneficiary letter. The district court granted summary judgment for the plaintiffs, agreeing with their argument that the decedent had substantially complied with the insurance company’s change-of-beneficiary procedures. The Seventh Circuit affirmed, agreeing that under the circumstances where there was no evidence to support the conclusion that the change of beneficiary was fraudulently obtained or made under undue influence that the decedent had substantially complied with the change of beneficiary procedures in his life insurance policy. (ST. EVE and KOLAR, concurring)