Sun Life Assurance Company of Canada v. Sheila Richardson v. Diana James

DeMOSS, Circuit Judge:

This case involves the application of Louisiana’s doctrine of substantial compliance as to the change of beneficiary in a life insurance policy. The district court found that Melvin Richardson substantially complied with the terms of his life insurance policy to effect a change of beneficiary. For the reasons stated herein, we conclude that the district court erred in such finding.

I. BACKGROUND

On June 29, 1989, Melvin Richardson (Melvin), who worked for Highlines Construction Company (Highlines), executed a written form changing the beneficiary of his life insurance…