Court of Appeals Digest: Oct. 7, 2024

This case required a decision as to decide whether Minnesota law or Connecticut law governed the enforceability of a beneficiary designation in a group life-insurance policy. Minnesota law automatically revokes the beneficiary designation of a spouse upon dissolution of a marriage, except in limited circumstances. Connecticut law does not. Appellant’s former spouse lived in Connecticut and designated appellant as her beneficiary under a group life-insurance policy issued to her Connecticut employer. She did not change that designation after appellant moved to Minnesota and a Minnesota court dissolved their marriage. Following the death of appellant’s former spouse, respondent insurer refused to pay appellant the death benefit under the policy. Appellant sued respondent for breach of contract. The District Court applied Minnesota law and granted summary judgment in favor of respondent on the breach-of-contract claim. On appeal, appellant argued that Connecticut law, not Minnesota law, governed whether appellant was entitled to the death benefit as the designated beneficiary under the policy.

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