In re Estate of Lucien Couture
166 N.H. 101
| N.H. | 2014Background
- Petitioner Thomas Couture sought a constructive trust over the decedent Lucien Couture’s life insurance proceeds paid to respondent Hellen Couture and her daughter, with the escrowed portion being her share.
- Decedent designated respondent and the daughter as life-insurance beneficiaries; fifty percent of the death benefit was paid to each.
- Respondent concealed a concurrent relationship with Tamara, raising a question of a confidential relationship and potential fraud in the marriage.
- Trial evidence showed respondent induced the marriage by deceit while concealing the relationship, and decedent designated respondent as a beneficiary during the marriage.
- The probate court imposed a constructive trust on respondent’s share to prevent unjust enrichment; respondent appealed; the appellate court affirmed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to seek a constructive trust | Couture has a direct legal interest as an heir. | Respondent contends petitioner lacks stake since benefits were paid under designation. | Petitioner has standing as an heir; standing exists. |
| ERISA exclusive jurisdiction | ERISA actions fall under federal exclusive jurisdiction. | Case involves ERISA benefits; federal courts should control. | Not an ERISA civil action; jurisdiction not exclusive to federal court. |
| ERISA preemption - express preemption | State-law constructive trust relates to post-disbursement benefits; preemption would be improper. | ERISA preempts state-law claims relating to benefit plans. | Not preempted; state-law constructive-trust claim survives post-disbursement context. |
| ERISA preemption - anti-alienation provision | Constructive trust does not contradict anti-alienation; post-disbursement recovery is allowed. | Anti-alienation bars enforcement in equity against plan benefits. | Anti-alienation does not preclude post-disbursement constructive trust. |
| Constructive trust standard and sufficiency of evidence | Fraud, confidential relationship, and unjust enrichment established by clear and convincing evidence. | Evidence insufficient or misapplied; no basis for trust. | Court properly imposed constructive trust; evidence supports it. |
Key Cases Cited
- Libertarian Party of N.H. v. Sec’y of State, 158 N.H. 194 (N.H. 2008) (standing and injury rules; standing requirements cited)
- In re Estate of Kelly, 130 N.H. 773 (N.H. 1988) (direct legal or equitable interest required for standing)
- Kennedy v. Plan Admin. for DuPont Sav. & Inv. Plan, 555 U.S. 285 (U.S. 2009) (ERISA plan administrator duties; distribution to named beneficiary; post-distribution implications)
- Estate of Kensinger v. URL Pharma, Inc., 674 F.3d 131 (3d Cir. 2012) (post-distribution recovery; constructive trust context; ERISA preemption discussion)
- Andochick v. Byrd, 709 F.3d 296 (4th Cir. 2013) (post-distribution ERISA considerations; constructive trust context)
- Hoult v. Hoult, 373 F.3d 47 (1st Cir. 2004) (ERISA anti-alienation; interpretation of post-distribution rights)