Aderholt v. McDonald
Decision Date | 16 December 2016 |
Docket Number | 1150878. |
Citation | 226 So.3d 648 |
Parties | Dolores ADERHOLT, as administrator of the Estate of Bobby Wayne Aderholt, deceased v. Sandra R. Aderholt MCDONALD |
Court | Alabama Supreme Court |
Lisa M. Ivey, Jasper; and James R. Beaird, Jasper, for appellant.
J. David Hood of Jackson, Fikes, Hood & Brakefield, Jasper, for appellee.
Dolores Aderholt ("Dolores"), as administrator of the estate of her deceased son Bobby Wayne Aderholt ("Bobby"), appeals the summary judgment entered by the Walker Circuit Court in favor of Sandra R. Aderholt McDonald ("Sandra"), Bobby's ex-wife, holding that Sandra was entitled to the proceeds of a $150,000 life-insurance policy Bobby held at the time of his December 2014 death. We affirm.
The relevant facts in this case are undisputed. On June 17, 1993, Alfa Life Insurance Corporation ("Alfa") issued a $150,000 life-insurance policy to Bobby ("the Alfa policy"), which provided that "[t]he beneficiary who will receive the policy proceeds at the death of the insured is named in the application." The application form in the record indicates that Bobby named Sandra, his wife at that time, as the sole beneficiary of the Alfa policy.
The divorce judgment further divided the parties' personal property and financial accounts and, relevant to this case, provided:
It appears that Bobby thereafter complied with the divorce judgment, maintaining Sandra as the beneficiary on the Alfa policy and paying her $500 per month until he died on December 12, 2014.
Following Bobby's death, Alfa received notice from both Dolores and Sandra that they were claiming the proceeds of the Alfa policy. Alfa accordingly initiated an interpleader action in the Walker Circuit Court, noting the competing claims and requesting that it be allowed to deposit the disputed insurance proceeds with the court so the court could determine which party was entitled to them. The circuit court granted Alfa's request and, after Alfa deposited $154,109 with the court—representing the proceeds of the Alfa policy, a premium refund, and accumulated interest—Alfa was dismissed from the action pursuant to Rule 22(b), Ala. R. Civ. P., which provides that "[a]ny party seeking interpleader ... may deposit with the court the amount claimed, ... and the court may thereupon order such party discharged from liability as to such claims, and the action continued as between the claimants of such money or property."
Sandra thereafter moved the circuit court to enter a summary judgment in her favor awarding her the interpleaded funds based on the undisputed facts that she was the named beneficiary of the Alfa policy and that the divorce judgment had required Bobby to keep her as the beneficiary of the Alfa policy for 15 years, or until September 2019. Dolores opposed Sandra's summary-judgment motion, arguing that the divorce judgment had required Bobby to maintain Sandra as the beneficiary of the Alfa policy for a period of 15 years because, she argued, the Alfa policy was intended to secure the 15 years of monthly $500 alimony-in-gross payments, not to function as an award in itself. Dolores accordingly argued that Sandra was entitled to, at most, a sum equal to the remaining unpaid alimony-in-gross payments, which she stated totaled $28,500,1 and that the rest of the interpleaded funds properly belonged to Bobby's estate.2 On May 5, 2016, the circuit court granted Sandra's motion and entered a summary judgment in her favor, explaining that On May 12, 2016, Dolores filed this appeal.
Dolores seeks the reversal of the summary judgment awarding the interpleaded funds to Sandra. We review a summary judgment pursuant to the following standard:
Dow v. Alabama Democratic Party, 897 So.2d 1035, 1038–39 (Ala. 2004).
The law of Alabama is that "the designation of the beneficiary of a life insurance policy is governed by the provisions of the policy itself." Gibson v. Henderson, 459 So.2d 845, 847 (Ala. 1984) (citing Williams v. Williams, 438 So.2d 735 (Ala. 1983) ). The Alfa policy provides that the beneficiary is the individual designated as the beneficiary on the application form; it is undisputed that the individual designated as the beneficiary on that form in this case is Sandra. There is no evidence in the record indicating that Bobby ever attempted to remove Sandra as the beneficiary of the Alfa policy or that he even desired to do so but was prevented from acting by the terms of the divorce judgment.
This Court has made it clear that a divorce, by itself, has no impact on one spouse's status as the beneficiary of the other spouse's life-insurance policy.3 In Flowers v. Flowers, 284 Ala. 230, 237–38, 224 So.2d 590, 596–97 (1969), this Court rejected an attempt by the administrators of the deceased ex-husband's estate to claim the proceeds of a life-insurance policy that named his ex-wife the beneficiary, explaining:
See also Kowalski v. Upchurch, 186 So.3d 460, 463 (Ala. Civ. App. 2015) ( ). This legal principle stems from the fact that any rights a beneficiary has to the proceeds of a life-insurance policy are contractual, not marital. Rountree v. Frazee, 282 Ala. 142, 147, 209 So.2d 424, 427 (1968).
In spite of this principle, Dolores argues that both Alabama state and federal courts have, under certain circumstances, disregarded a party's presumptive contractual rights to the proceeds of a...
To continue reading
Request your trial