Standard Insurance Co. v. Schwalbe

At issue is the efficacy of a beneficiary change on a group term life insurance policy in violation of a preliminary injunction issued in a dissolution action. We hold that a trial court may void a change in beneficiary made in violation of a preliminary injunction and the subsequent death of the violator is no bar to the exercise of such power.

Facts

The facts are not in dispute. William Schwalbe filed a petition for dissolution of his marriage to Joanne Schwalbe in September 1985. On October 17, 1985, the trial court awarded temporary custody of the Schwalbes' three minor children to Mrs.…