Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation and good law / bad law checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
National Home Life Assurance Co. v. Patterson
Citations: 746 P.2d 696; 1987 OK CIV APP 65; 1987 Okla. Civ. App. LEXIS 160Docket: 64361, 64362
Court: Court of Civil Appeals of Oklahoma; September 8, 1987; Oklahoma; State Appellate Court
The case involves two interpleader actions concerning insurance proceeds from policies held by the deceased, Patsy Jatonii Adair. Following her murder by her husband, who is serving a life sentence, the trial court denied the motions for summary judgment filed by the appellants—her children and the estate executrix—and granted judgment to the appellee, Joann Adair, the stepchild of the deceased. Decedent's will designated her husband as the primary beneficiary and her children and Joann as residual beneficiaries. The insurance policies stipulated that if the primary beneficiary is unable to claim the proceeds, they would be divided among the children or paid to the estate's executor. Oklahoma's "slayer statute" disqualifies a beneficiary convicted of murdering the insured from receiving benefits. All parties agree the husband is disqualified under this statute. The trial courts ruled that the insurance proceeds should be deposited into the estate and distributed according to the will. The appeals focus on whether this ruling was legally erroneous, highlighting that insurance proceeds are contractual matters and should be interpreted under contract law principles. The outcome hinges on the legal interpretation of the insurance policies and the applicability of the will in light of the statute. The National Home Life insurance policy stipulates that proceeds are to be distributed first to the primary beneficiary; if unavailable, to the insured's children in equal shares. Decedent's convicted husband cannot receive any proceeds due to his murder conviction. It is determined that an unadopted stepchild does not qualify as a "child" under the policy, thus is not entitled to proceeds. The trial court erred by ordering the proceeds to be included in the Decedent's estate for distribution via the Last Will and Testament, as the insurance contract explicitly outlines the distribution method. For the Life General Insurance policy, proceeds are directed to the primary beneficiary or, if that person cannot take them, to the owner of the policy or the personal representative of the estate. The trial court correctly ruled that the proceeds should go to the personal representative. The opinion affirms the explicit terms of the insurance contracts, acknowledges the Decedent's Will regarding other estate assets, and clarifies that the slayer statute does not apply in the contexts presented. The trial court's orders are partially affirmed and partially reversed, with instructions to ensure the National Home Life policy proceeds are paid directly to Decedent’s three natural children and the Life General policy proceeds are paid to the estate's personal representative.