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Erie Family Life Insurance Co. v. Sampson

Court of Appeals of Tennessee, Nashville

June 28, 2017

ERIE FAMILY LIFE INSURANCE COMPANY
v.
TIFFANY DAWN SAMPSON, ET AL.

          Assigned on Briefs December 2, 2016

         Appeal from the Circuit Court for Robertson County No. 74CC1-2014-CV-33 Ross H. Hicks, Judge

         Insurer brought a declaratory judgment action asking the court to determine the proper beneficiary of the proceeds of a life insurance policy rider insuring the life of the named insured's child; the named insured had designated her mother as the beneficiary of the policy and rider. Upon the child's death, the named insured was prevented by law from receiving the proceeds, and the insurer asked for a declaration of whether the named insured's disqualification also prevented the named beneficiary from receiving the proceeds or whether the estate of the child would receive the proceeds, in accordance with the designation of beneficiary in the policy. The trial court determined that the policy's designation was inequitable and awarded the proceeds to the estate of the child. We have determined that the disqualification of the named insured from receiving the proceeds of the policy does not invalidate the designation of beneficiary and, accordingly, reverse the decision of the trial court.

         Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Circuit Court Reversed; Case Remanded.

          Benjamin K. Dean, Springfield, Tennessee, for the appellant, Lynne Clark Meeks.

          S. Morris Hadden and Caroline Ross Williams, Erie, Pennsylvania, for the appellee, Erie Family Life Insurance Company.

          Anthony Maldonado, Hermitage, Tennessee, Pro Se. Tiffany Dawn Sampson, Greenbrier, Tennessee, Pro Se.

          H. Garth Click, Springfield, Tennessee, Guardian ad litem, for the minor siblings.

          Richard H. Dinkins, J., delivered the opinion of the court, in which D. Michael Swiney, C.J., and Arnold B. Goldin, J., joined.

          MEMORANDUM OPINION [1]

          RICHARD H. DINKINS, JUDGE

         On February 21, 2012, Erie Family Life Insurance Company ("Erie") issued to Tiffany Sampson a twenty-year term life insurance policy insuring her life; Lynne Meeks, Ms. Sampson's mother, was named as the beneficiary of the life insurance policy. At the time the policy was issued, Ms. Sampson was the mother of four children: Lindsey, Landon, Logan, and Adrian. Ms. Sampson also purchased a Children's Term Insurance Rider ("the Rider"), insuring the life of each child in the amount of $10, 000.00. The Rider contained the following language:

         BENEFICIARY. The beneficiary of this rider is:

1. first, the insured, if living; ...

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