12 N.W.3d 768
Minn. Ct. App.2024Background
- Decedent, Philippa Scott, a Connecticut school employee, purchased a group life-insurance policy—issued in Connecticut by Minnesota Life Insurance Company—and named her spouse, Carley Pesente, as beneficiary.
- Scott and Pesente married and lived in Connecticut, but later separated, with Pesente relocating to Minnesota, while Scott remained in Connecticut.
- Their marriage was dissolved by a Minnesota court, which did not address the life insurance policy or beneficiary designation in its judgment.
- After Scott's death in Connecticut, Minnesota Life refused to pay the death benefit to Pesente, claiming that Minnesota's revocation-on-divorce statute automatically removed Pesente as beneficiary; payment was made to Scott's mother instead.
- Pesente sued for breach of contract in Minnesota court, asserting Connecticut law should govern, as it would honor the original beneficiary designation regardless of the dissolution.
- The district court granted summary judgment for Minnesota Life, applying Minnesota law. Pesente appealed.
Issues
| Issue | Pesente's Argument | Minnesota Life's Argument | Held |
|---|---|---|---|
| Which state law governs beneficiary designation? | Connecticut law governs, as policy was issued there to a CT employer and insured; decedent resided in CT. | Minnesota law governs due to the divorce and because both parties now have MN ties. | Connecticut law governs; district court erred. |
| Does Minnesota’s revocation-on-divorce statute apply to a beneficiary designation if marriage dissolved in MN? | Statute does not apply; policy and insured have no significant Minnesota connection. | Statute applies automatically upon Minnesota dissolution. | Statute does not apply; Connecticut law should decide enforceability. |
| Should the significant contacts/choice-of-law factors analysis be used? | Yes, and factors favor Connecticut (predictability, expectations, policy location). | Factors, especially Minnesota’s state interest, favor Minnesota. | Choice-of-law factors require application of Connecticut law. |
| Does the Restatement (Second) of Conflict of Laws § 192 cmt. h control? | It should control and require Connecticut law to apply. | It does not override Minnesota’s five-factor test. | Comment h is persuasive but not controlling; five-factor test is proper approach. |
Key Cases Cited
- Jepson v. Gen. Cas. Co. of Wis., 513 N.W.2d 467 (Minn. 1994) (establishes five-factor choice-of-law test for contract disputes)
- In re Est. of Tomczik, 992 N.W.2d 691 (Minn. 2023) (explains Minnesota’s revocation-on-divorce statute and its policy rationale)
- Nodak Mut. Ins. Co. v. Am. Fam. Mut. Ins. Co., 604 N.W.2d 91 (Minn. 2000) (defines actual conflict for choice-of-law purposes)
- Milkovich v. Saari, 203 N.W.2d 408 (Minn. 1973) (adopts the five choice-influencing factors for Minnesota)
- Schumacher v. Schumacher, 676 N.W.2d 685 (Minn. App. 2004) (clarifies that choice-of-law questions are reviewed de novo)