Estate of Charles Allen Lane v. Amanda Davenport Courteaux, M2016-00609-COA-R3-CV

Background

Decedent Teresa Lane had a $600,000 life insurance policy, originally naming her husband Charles Lane sole beneficiary; about four weeks before her unexpected death in Nov. 2013 she added her sister Amanda Courteaux as a co‑beneficiary, splitting proceeds $300,000 each.
Son Conner (a minor at his mother’s death) and husband (later deceased) asserted Decedent intended Amanda’s share to be used for Conner’s care; Decedent left a handwritten list (Exhibit 1) expressing distribution wishes.
Husband filed suit seeking to place $270,000 of Amanda’s $300,000 into a trust for Conner, pleading reformation, constructive trust, promissory estoppel, and unjust enrichment; a temporary restraining order prevented Amanda from spending proceeds pending resolution.
Trial court found promissory estoppel: Amanda promised to care for Conner and Decedent relied by naming her as beneficiary; awarded Conner $297,855.48 (Amanda’s share minus funeral expenses).
Amanda appealed; the Court of Appeals reversed, holding a valid beneficiary designation controls when no legal mandate required a different beneficiary and equitable remedies cannot defeat an unambiguous insurance designation.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether extrinsic evidence of the insured’s intent or promises can defeat the named beneficiary’s statutory/contractual right to policy proceeds	Estate/Conner: Decedent intended Amanda’s share for Conner; reliance and promises support equitable relief	Courteaux: Insurance policy designation controls; intent or will-like documents cannot divest a named beneficiary	Held for Courteaux — beneficiary designation governs; evidence of intent does not deprive named beneficiary of proceeds
Whether promissory estoppel can be used to recover insurance proceeds paid to a named beneficiary	Estate/Conner: Amanda promised to care for Conner and Decedent relied; promissory estoppel justifies recovery	Courteaux: Equitable estoppel cannot override clear contract rights under the policy	Held against Estate/Conner — promissory estoppel cannot defeat the beneficiary designation in these facts
Whether a constructive trust or unjust enrichment remedy should be imposed on Amanda’s share	Estate/Conner: Imposition justified because Decedent intended funds for Conner and Amanda’s retention would be unjust	Courteaux: No legal mandate or contract defect; equitable remedies cannot alter an unambiguous contractual beneficiary	Held against Estate/Conner — equitable remedies precluded where express policy terms control
Whether legal mandates or prior orders required a specific beneficiary, creating an equitable interest	Estate/Conner: (alternative) prior statements/dealings create equitable claim	Courteaux: No court order, decree, or contractual obligation required a particular beneficiary	Held for Courteaux — cases imposing constructive trusts involved legal mandates (e.g., divorce decree); none exist here

Key Cases Cited

McKimm v. Bell, 790 S.W.2d 526 (Tenn. 1990) (insurance policy is contract between insured and insurer; interpret policy language)
Interstate Life & Accident Ins. Co. v. Gammons, 408 S.W.2d 397 (Tenn. Ct. App. 1966) (insured’s intent irrelevant when policy language is clear)
Stoker v. Compton, 643 S.W.2d 895 (Tenn. Ct. App. 1981) (policy proceeds pass to named beneficiary despite conflicting will or oral gifts)
Bowers v. Bowers, 637 S.W.2d 456 (Tenn. 1982) (property settlement or post‑marriage agreements do not defeat named beneficiary absent compliance with policy procedure)
Holt v. Holt, 995 S.W.2d 68 (Tenn. 1999) (constructive trust may be imposed where a legal mandate, such as a marital dissolution agreement, vests an equitable interest in a designated beneficiary)
Dossett v. Dossett, 712 S.W.2d 96 (Tenn. 1986) (divorce decree requiring beneficiary designation creates vested equitable interest enforceable against proceeds)
Goodrich v. Mass. Mut. Life Ins. Co., 240 S.W.2d 263 (Tenn. Ct. App. 1951) (requiring compliance with decree/mandate before beneficiary change is effective)
Metro. Life Ins. Co. v. Bryant, 191 S.W.2d 449 (Tenn. Ct. App. 1945) (insurance proceeds do not pass by will to defeat named beneficiary)