The Ontario Court of Appeal has granted a stay of its controversial judgment in Carrigan v. Carrigan Estate pending the outcome of an application for leave to appeal to the Supreme Court of Canada. As discussed in an earlier article, the Appeal Court’s decision has wide ranging implications for administrators of pension plans with members whose benefits are subject to the Ontario Pension Benefits Act  and raises important issues for plan administrators in other jurisdictions as well. Pending the outcome of the application or the disposition of the appeal, pension plan administrators must be mindful of how they deal with the payment of death benefits following the death of plan members, especially in circumstances involving more than one spouse.