Insurance: ERISA-Payment of Benefits to Domestic Partner-Deference to Plan Administrators

Defendants appealed from the declaratory judgment that ruled that defendants paid group life-insurance benefits to the wrong person. Terry Engle died in a car crash while holding accidental death and life-insurance policies with defendants. Defendants contacted Terry’s mother, who informed defendants that Terry lived with a domestic partner; defendants interpreted the plans to consider a domestic partner the equivalent of a spouse and paid benefits to Terry’s partner. Plaintiff filed suit, arguing that defendants should have paid benefits to Terry’s children.

Where defendants’ interpretation of the term spouse to include domestic partners was not an unreasonable interpretation, the district court erred by imposing an alternative interpretation and not deferring to defendants as the plan administrator.

Judgment is reversed and remanded.

Engle v. Land O’Lakes Inc. (MLW No. 73874/Case No. 18-2821 – 7 pages) (U.S. Court of Appeals, 8th Circuit, Arnold, J.) Appealed from U.S. District Court, Western District of Missouri, Hays, J. (Christopher J. Leopold, of Kansas City for appellant; William E. Hanna, of Kansas City on brief) (Karl Wilson Blanchard Jr., of Joplin for appellee)