Estate of Irvine v. Oaas, 309 P.3d 986

John W. Irvine Jr. executed beneficiary-designation forms (2003–2006) for three investment accounts: Hartford (named Deana primary; "estate of the annuitant" contingent), Pacific Life (same), and Northwestern (named Deana primary; no contingent).
Deana (John's spouse) died in August 2008; John died June 30, 2009; proceeds from all three accounts were paid to John's estate.
Va Va Irvine (John's mother) sought declaratory judgment claiming she was the intended contingent beneficiary of the accounts; Michael Dodge (Deana's son) opposed and moved for summary judgment.
Va Va relied on testimony from John's financial planner, Steven Daniel, who said John told him he wanted proceeds to go to Deana, and if Deana predeceased him then to Va Va or John's brother; Daniel testified he filled out forms naming John's estate as contingent because he believed John had no will.
Va Va argued the designations should be reformed for mutual/unilateral mistake or that extrinsic evidence should control; the district court granted summary judgment to Dodge, concluding reformation was inappropriate and the contracts were unambiguous.
The Montana Supreme Court affirmed, holding there was no clear-and-convincing evidence of mistake justifying reformation and that the written beneficiary terms unambiguously entitled the estate to the proceeds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether beneficiary-designation contracts may be reformed to name Va Va as beneficiary	Va Va: Daniel's testimony shows John intended proceeds to pass to Va Va if Deana predeceased him; mistake (Daniel's belief John had no will) justifies reformation	Dodge: Contracts reflect John's decision to name his estate or leave no contingent; no clear-and-convincing evidence of mistake; reformation cannot be used to insert a new beneficiary	Court: Denied reformation. No clear-and-convincing proof of mistake; permitting a stranger to add herself as beneficiary would create a new contract beyond reformation relief
Whether proceeds were properly paid to John's estate under the contract terms	Va Va: Extrinsic evidence should control to carry out John’s intent	Dodge: Written beneficiary designations are clear and unambiguous; terms require payment to estate	Court: Affirmed. Designations unambiguous; estate was proper recipient (including Northwestern account where contract allowed payment to executors/administrators if no surviving named beneficiary)

Sullivan v. Marsh, 225 P.2d 868 (Mont. 1950) (mutual intent standard for reformation)
Rogers v. Relyea, 601 P.2d 37 (Mont. 1979) (court may not make "new and different" contract or add significant terms by reformation)
Laundreville v. Mero, 281 P. 749 (Mont. 1929) (reformation of donative instruments for unilateral mistake of donor)
Pullum v. Pullum, 58 So. 3d 752 (Ala. 2010) (reformation to correct mistaken property descriptions)
Magnuson v. Diekmann, 689 N.W.2d 272 (Minn. Ct. App. 2004) (reformation applied to deed to reflect donor’s intent)
Bradbury v. Higginson, 140 P. 254 (Cal. 1914) (statute like Mont.'s § 28-3-304 cannot be used to add provisions not appearing in written contract)