Briggs v. Liddell

ZIMMERMAN, Justice:

This is an appeal from a trial court determination that decedent had mistakenly designated her sister, defendant, as the primary rather than the contingent beneficiary under a life insurance policy and that allowed reformation of the contract in favor of decedent’s husband, plaintiff. Because reformation of a contract may not be granted upon a showing of unilateral mistake, and because there is no substantial record evidence to support a finding of mutual mistake, we reverse.

Marjorie and Charles Briggs opened a joint checking account at the Bank of Utah. At the same time,…