Hill v. DeWitt

These two cases, which we consolidated for purposes of this opinion, concern the question of whether a designation of a spouse as beneficiary of a life insurance policy survives the dissolution of marriage. Prior to July 1, 1995, Colorado law provided that the dissolution of marriage did not revoke a former spouse's designation as beneficiary of a life insurance policy absent an intent to the contrary expressed by the insured. See, e.g., Napper v. Schmeh, 773 P.2d 531, 533 (Colo.1989); Christensen v. Sabad, 773 P.2d 538, 540 (Colo.1989); Mullenax v. Nat'l Reserve Life Ins. Co., 29 Colo.App.…