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Prudential Insurance Company of America v. Mary Beth Kamrath, United States Court of Appeals for the Eighth Circuit

Following Bradley Kamrath’s 2003 death, both his wife and sister claimed beneficiary rights to his $500,000 life insurance policy. Complicating the matter, Mr. Kamrath had made efforts to name his sisteras beneficiary amid his ongoing divorce proceedings with his wife. However, Mr. Kamrath had not submitted the proper forms to enact the beneficiary change prior to his death and in notes to his family had left reasonable indications that he believed Mrs. Kamrath would be the policy beneficiary.

Prudential Insurance Company of America, the policy holder, filed a 2007 interpleader action to resolve the competing claims.

In a decision that was subsequently affirmed by the 8th U.S. Circuit Court of Appeals, the U.S. District Court for the Eastern District of Missouri found that Mr. Kamrath’s efforts to change the policy beneficiary were not substantive enough to meet the requirements for the application of the substantial-compliance doctrine.

Ms. Kamrath, represented by David Steelman, was affirmed as the policy beneficiary.

Disclaimer: Past results afford no guarantee of future results. Every case is different and must be judged on its own merits.