Barbara Jane Irwin v. Mike Irwin, as Representative of the Estate of Richard Lee Irwin
This appeal concerns a summary judgment in favor of the Estate of Richard Lee Irwin against his ex-wife, Barbara Jane Irwin. Richard, an employee of the DEA, had designated Barbara as the primary beneficiary of his FEGLIP life insurance policy, with his sons Mike and John as contingent beneficiaries. After their divorce, Richard updated his will to exclude Barbara but never changed his life insurance beneficiary designation. Upon Richard's death, Barbara received the policy proceeds. Mike, representing Richard's estate, sued Barbara to recover the proceeds, claiming the estate had standing. The trial court granted summary judgment for the estate, imposing a constructive trust on the proceeds. The appellate court reversed and remanded the decision, ruling that the estate lacked standing as it was not a designated beneficiary and life insurance proceeds are nontestamentary assets. The court noted that Mike and John, as contingent beneficiaries, would be the proper plaintiffs.