Deceased Public Safety Officer’s Failure to Name Surviving Fiancée as Beneficiary of Life Insurance Policy Led to Denial of Death Benefits Claim
San Diego County Sheriff's Deputy Kenneth Collier died while on patrol. Collier was survived by his fiancée, Karen Li. Although Collier had told Li and their friends, including through video footage, that he had made arrangements for Li to be "taken care of," the beneficiary designation form for Collier's life insurance designated his mother, who predeceased Collier, as primary beneficiary and his ex-girlfriend as contingent beneficiary. The ex-girlfriend and Li ultimately arrived at a settlement, which the insurance company honored. Thereafter, Li applied for death benefits under 34 U.S.C. §10281(a) (The Public Safety Officers' Benefits Act, PSOB), which directs the Bureau of Justice Assistance (BJA) to pay a death benefit to an appropriate claimant when an officer is killed in the line of duty. The BJA denied the claim on the grounds that Li had failed to show she was a designated beneficiary of a "legal and valid" life insurance policy; a required element to support a PSOB benefits claim.
Li appealed, arguing that the BJA did not properly consider the totality of the circumstances, including the video footage, Collier's statements, and the prior settlement. The Court of Appeals for the Federal Circuit affirmed the denial of benefits. The court held, in part, that Congress intended a decedent's most recent life insurance policy to be determinative of the proper beneficiary for PSOB benefits. Because section 10281(a)(4)(B) and California state insurance law requires strict compliance, the court said Li's totality-of-the-circumstances test lacked merit, and the BJA's findings were not arbitrary, capricious, or unsupported by the evidence.
Jeff Sodoma, MPA, Esq. is a lawyer based in Virginia Beach, Virginia
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