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Desia v. GE Life & Annuity Assurance Co.

Citation: 350 F. App'x 542Docket: No. 08-5641-cv

Court: Court of Appeals for the Second Circuit; October 28, 2009; Federal Appellate Court

Narrative Opinion Summary

The case involves an appeal by the trustee of the Barbara Bess Trust for Julius Solomon against GE Life Annuity Assurance Co., concerning the designation and payment of annuity proceeds. The trustee, as the plaintiff, contended that GE breached contractual obligations by distributing annuity proceeds to Bess's sisters instead of to the Solomon trust. The legal question centered around whether Bess intended to designate the Solomon trust as the beneficiary, an assertion the plaintiff supported with insufficient evidence. The court conducted a de novo review of the summary judgment, affirming it on the basis that there was no genuine issue of material fact regarding Bess's intent. Evidence presented by the plaintiff, including speculation about Bess's intent and challenges to the credibility of Bess’s financial adviser, did not meet the threshold required to overturn the judgment. The decision ultimately upheld the lower court's ruling in favor of GE, dismissing the trustee's arguments as lacking merit and finding no basis for altering the payment of the annuity proceeds.

Legal Issues Addressed

Burden of Proof for Designation of Beneficiary

Application: Desia failed to provide sufficient evidence that Bess intended to designate the Solomon trust as the beneficiary, making speculative claims insufficient to create a triable issue.

Reasoning: Desia argues the district court incorrectly determined that she did not present sufficient evidence of Bess’s intent to designate the Solomon trust as the beneficiary.

Credibility and Material Fact in Summary Judgment

Application: Broad attacks on a witness's credibility, such as those against Stewart, do not create material fact questions without specific evidence.

Reasoning: The court maintained that broad attacks on credibility do not, by themselves, create material fact questions.

Standard for Reviewing Summary Judgment

Application: The court reviews the summary judgment de novo and affirms if no genuine issue of material fact exists.

Reasoning: The court reviews the summary judgment de novo, affirming if no genuine issue of material fact exists.