Cehovic-Dixneuf v. Wong

895 F.3d 927 (7th Cir. 2018)

Words & Phrases

ERISA

Trial Judge

Samuel Der-Yeghiayan

Appellate Judge

Hamilton

Holding

Life insurance policy was governed by ERISA. even though deceased had paid all premiums without any direct subsidy by his employer, where employer maintained substantial administrative functions associated with policy.

Fact Summary

The federal Employee Retirement Income Security Act of 1974 (ERISA) requires administrators of employee benefit plans to comply with the documents that control the plans. 29 U.S.C. § 1104(a)(1)(D). In the case of life insurance policies, that means death benefits are paid to the beneficiary designated in the policy, notwithstanding equitable arguments or claims that others might assert.

In this case, the deceased employee was Georges Cehovic, whose employer offered its employees an insurance benefit plan through ReliaStar Life Insurance Company. Georges had two policies under the plan with ReliaStar: a basic life insurance policy with a death benefit of $263,000, and a supplemental life insurance policy with a death benefit of $788,000. On both policies, Georges listed his sister, plaintiff Emma Cehovic‐Dixneuf, as the sole and primary beneficiary. After Georges died, his ex‐wife, defendant Lisa Wong, claimed that she and the child she had with Georges were entitled to the death benefits from the supplemental policy. Any equitable arguments Wong might make can gain no traction, however, if the supplemental life insurance policy is covered by ERISA.

The district court granted summary judgment for plaintiff Cehovic‐Dixneuf, finding that the supplemental life insurance policy is indeed covered by ERISA. We affirm. Defendant Wong failed to offer evidence to the district court showing any genuine issue of any fact material to the case. She did not present her evidentiary objections to Cehovic‐Dixneuf’s evidence in the district court when she could and should have.

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