Union Security Insurance v. Blakeley

OPINION

THAPAR, District Judge.

In an unusual turn of events, ERISA makes this a simple case. To determine the proper beneficiary of Thomas Blakeley’s life insurance policy, ERISA says to look first at the text of the policy. But the court below overlooked a key piece of the policy’s text and instead resorted to the common law to decide that Sondra Billet was the rightful beneficiary. This was error.

I

When he died in December 2007, Thomas Blakeley left behind three children, a cohabitant and purported fiancée named Sondra Billet, and a life insurance policy for which he neglected to select a…