Protective Life Ins. Co. v. Hansen

Dist. Ct. did not err in granting defendant-employer's motion for summary judgment in instant interpleader action filed by insurance company to determine ownership of life insurance proceeds on $1 million policy taken out by employer in name of key employee, after finding that employer was entitled to said proceeds as named beneficiary of said policy. While employer had intended to allow policy to lapse, record showed that liquidator of employer had unsuccessfully attempted to submit forms to insurance company to transfer ownership of policy to key employee, who in turn attempted to name his girlfriend as beneficiary of policy shortly before key employee committed suicide. Ct. rejected defendant-girlfriend's argument that she was entitled to reformation of policy to reflect actual name of employer so as to effectuate liquidator's failed attempt to transfer ownership of policy to key employee where it was unclear whether, upon any reformation, insurance company would have actually made said transfer. Moreover, Ct. rejected girlfriend's alternative argument that she was third-party beneficiary of insurance contract between employer and insurance company.