Crites v. Anthem Life Ins. Co.
2013 Ohio 2145
Ohio Ct. App.2013Background
- Decedent Keith L. Crites had a $30,000 ERISA group life policy naming his children as beneficiaries, later changed to B. Crites with children as contingent beneficiaries.
- In 2010, decedent and B. Crites divorced; separation agreement released each party’s rights to the other's life-insurance policy.
- Decedent died on April 10, 2010, triggering ERISA-governed proceeds.
- Litigation commenced in 2011: children sued Anthem for the death benefit; Anthem sought to deposit funds; B. Crites counter-claimed for payment.
- Stipulations in Dec. 2011 acknowledged ERISA governance, plan documents naming B. Crites as beneficiary, and separation agreement waivers of rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ERISA plan controls and overrides state-law waivers on beneficiary designations. | Crites argued the plan requires paying to the named beneficiary per plan documents. | Crites alleged waiver by separation agreement divested the named beneficiary rights. | ERISA plan controls; court must pay to named beneficiary; judgment reversed. |
Key Cases Cited
- Egelhoff v. Egelhoff ex rel Breiner, 532 U.S. 141 (U.S. 2001) (plan documents govern benefits; ERISA preempts state law)
- Kennedy v. Plan Adm’r. for Dupont Sav. and Inv. Plan, 555 U.S. 285 (U.S. 2009) (absence of a valid QDRO requires following plan beneficiary designation)