Beltway Paving Company, Inc. v. Prudential Insurance Company of America, 8:21-cv-00264

Beltway Paving Company (Beltway) purchased two life insurance policies on the life of its minority owner, Timothy Moore: a 2015 policy with Beltway as beneficiary, and a 2017 policy which listed Michael Williams (another shareholder) as beneficiary, and Moore’s estate as contingent beneficiary.
Beltway paid all premiums for both policies; the 2015 policy paid out to Beltway upon Moore’s death, but the 2017 policy’s proceeds went to Moore’s estate after Williams (the primary beneficiary) predeceased Moore.
Beltway sued Pruco Life Insurance (the insurer) and the Estate of Moore for unjust enrichment, seeking declaration that Beltway was entitled to the 2017 policy’s proceeds, arguing the “intended” beneficiary was Beltway.
No paperwork was ever completed to formally change the beneficiary of the 2017 policy prior to Moore’s death; discussions and recommendations to change the beneficiary did not result in action.
All parties moved for summary judgment. The court granted summary judgment to Pruco and the Estate, and denied Beltway’s motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to Policy Proceeds	Beltway was always the intended beneficiary; paid all premiums; estate’s receipt is unjust enrichment.	Insurance contract requires written beneficiary changes; Moore never completed or instructed such a change; estate is proper payee.	For Defendants; no change-of-beneficiary requirements satisfied, and no inequitable retention shown.
Equitable “Intent”/Unjust Enrichment	Moore expressed intent to change beneficiary to Beltway; estate should not keep funds it did not pay for.	Mere intent without action is insufficient; controlling law requires insured to do everything possible to effect change, which Moore did not.	Court finds no evidence Moore did everything to change beneficiary; intent alone is insufficient.
Effect of Premium Payments	Paying all premiums entitles Beltway to proceeds/equitable relief.	Employers often pay premiums as a perk, policy controls regardless of who paid premiums.	Paying premiums alone does not create equity in contravention of contract.
Failure to Act on Change	Moore's alleged instructions to brokers were sufficient; brokers failed to carry out change.	No credible evidence Moore instructed change; no written request ever sent; no external impediment to change.	Court finds no evidence of instruction or impediment—change not effectuated.

Daly v. Daly, 113 A. 643 (Md. 1921) (Equitable change of insurance beneficiary only if insured does all in their power to effect change)
Urquhart v. Alexander, 147 A.2d 213 (Md. 1958) (Mere intent to substitute beneficiary is not enough without action)
Berry & Gould, P.A. v. Berry, 757 A.2d 108 (Md. 2000) (Elements for unjust enrichment in Maryland)
Reid v. Durboraw, 272 F. 99 (4th Cir. 1921) (No change in beneficiary where insured failed to follow procedures despite opportunity)