Smith v. Locomotive Engineers Mutual Life & Accident Insurance

1. In mutual benefit associations the contract of insurance is between the association and the member. The interest of a beneficiary in a certificate on the life of a member of such association is a mere expectancy, which becomes vested only on the death of the member. Therefore the member may change his beneficiary without other limitations or restrictions than such as are imposed by statute, the articles of incorporation, the by-laws, or the certificates of the association, where no equities exist in favor of the original beneficiary. 4 Cooley’s Briefs on Insurance, 3756, 3758; Niblack’s…