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Keywords

trialsummary judgmentdeclaratory judgment
trialwillappellantappellee

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Rowland v. Faulkenbury, 47 Ark. App. 12, 883 S.W.2d 848

Facts

Joyce Blankenship was murdered on November 20, 1990, while having a life insurance policy with John Hancock Mutual Life Insurance Company. The policy designated her son, James Guss, as the beneficiary of 75% of the proceeds and Charles Faulkenbury as the beneficiary of 25%. After Guss was convicted of murdering Blankenship, he was disqualified from receiving any proceeds, leading Faulkenbury to seek a declaratory judgment to determine his entitlement to the proceeds.

The decedent in this life insurance case, Joyce Blankenship, was murdered on November 20, 1990. At the time of her death she had in force a policy issued by John Hancock Mutual Life Insurance Company which designated James Guss, her son, as beneficiary of 75 percent of the proceeds, and the appellee, Charles Faulkenbury, as beneficiary of 25 percent of the proceeds.

Issue

Whether the proceeds of the life insurance policy should be distributed to the named beneficiary, Charles Faulkenbury, or to the mother of the insured, Bertha Rowland, as the nearest surviving relative.

At issue in the proceedings was whether the 75 percent of the proceeds, which Mr. Guss was disqualified from receiving as a result of having murdered the insured, was distributable to appellee as the only other named beneficiary or to the appellant, in her individual capacity, as the nearest surviving relative of the insured.

Rule

The court held that a beneficiary convicted of murdering the insured forfeits all rights to the proceeds of the life insurance policy, and that the policy's provisions regarding beneficiaries are to be interpreted according to the intent expressed in the policy.

The willful, unlawful and felonious killing of the assured by the person named as beneficiary in a life policy forfeits all rights of such person therein.

Analysis

The court found that the beneficiary designation was clear and unambiguous, stating that the insured's family would only receive proceeds if no beneficiary was named or survived the insured. Since Guss was disqualified due to his conviction, the court ruled that Faulkenbury, as the only other named beneficiary, was entitled to the proceeds. The court also determined that the assignment of benefits by Guss to the funeral service was invalid, as he had no interest to assign.

We agree with the trial court that the beneficiary designation form clearly provides that the insured's family or estate collects the proceeds only if no designated (or named) beneficiary survives the insured, or if the insured has failed to designate (or name) a beneficiary.

Conclusion

The court affirmed the trial court's decision, granting summary judgment to Charles Faulkenbury and ruling that he was entitled to the life insurance proceeds.

Affirmed.

Who won?

Charles Faulkenbury prevailed in the case because the court determined that he was the only valid beneficiary remaining after the disqualification of James Guss due to his conviction for murder.

The court's final decision or holding in 1–2 sentences.

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