McLaughlin v. Hartford Life & Annuity Insurance Company
Civil Action No. 2017-0500
| D.D.C. | Oct 25, 2017Background
- John J. McLaughlin designated Christina Vidal beneficiary of two annuity contracts in 1996; they married in 1997 and executed a prenuptial agreement the same year.
- The prenup provided a $1,000,000 lump-sum payment to Vidal in the event of divorce and included a waiver clause concerning spousal rights to pensions/death benefits, while excepting any beneficiary designations made after the agreement.
- The D.C. Superior Court enforced and incorporated the prenup into the 2010 divorce judgment; Vidal received the $1,000,000 settlement.
- McLaughlin died in Washington, D.C., in August 2016 without naming a contingent beneficiary; plaintiff (personal representative of the estate) sued to declare the estate sole beneficiary.
- Vidal was served but did not respond; default was entered and plaintiff moved for default judgment. The court ordered supplemental briefing on whether the divorce/prenup revoked Vidal’s beneficiary status for the annuities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject-matter jurisdiction | Diversity exists: estate (D.C.) v. Vidal (CT) and amount > $75,000 | Not disputed | Court: Diversity jurisdiction exists |
| Personal jurisdiction over Vidal | D.C. contacts (marriage, residence, divorce, decedent’s death, annuity transactions) support jurisdiction | Not argued (default) | Court: Specific jurisdiction proper under D.C. law and due process |
| Whether divorce/"implied revocation" automatically extinguishes beneficiary of annuity | Implied revocation doctrine should apply to annuities, revoking Vidal’s designation | Not argued (default); courts have been reluctant to extend implied revocation beyond wills | Court: Declines to decide applicability of implied revocation to annuities because unnecessary to disposition |
| Whether the prenup/divorce revoked Vidal’s beneficiary status | Prenup and divorce settlement extinguished Vidal’s interest in annuities | Not argued (default) | Court: Prenuptial agreement (Paragraph 8) provides clear and convincing evidence that parties intended divorce to terminate Vidal’s beneficiary status; estate is sole beneficiary |
Key Cases Cited
- Estate of Liles v. Wiley, 435 A.2d 379 (D.C. 1981) (announcing D.C. "implied revocation" doctrine for wills)
- Bolle v. Hume, 619 A.2d 1192 (D.C. 1993) (noting limits on extending implied revocation beyond wills)
- Estate of Bowden v. Aldridge, 595 A.2d 396 (D.C. 1991) (requiring convincing evidence that separation/settlement intended to deprive named beneficiary of interest)
- Mayberry v. Kathan, 232 F.2d 54 (D.C. Cir. 1956) (general waiver language insufficient to show intent to forfeit death benefits)
- Thomson v. Thomson, 156 F.2d 581 (8th Cir. 1946) (absence of mention of insurance in settlement undermines claim that settlement intended to alter beneficiary status)