The US District Court for the Northern District of Ohio recently ruled that a deceased participant’s daughter was entitled to the entire proceeds of his employer-provided life insurance policy despite the fact that his spouse was named as the primary beneficiary. The participant’s first marriage ended in divorce, and the resulting divorce decree ordered the participant to name his daughter from the marriage as the 100 percent beneficiary of his “life insurance policy plans as available through employment.” The participant later remarried and executed a beneficiary form naming his second wife as the primary beneficiary entitled to 100 percent of the policy proceeds instead. After the participant died, his daughter and second wife filed competing claims to the policy proceeds, and the dispute was brought before the district court. The daughter claimed that she was entitled to the entire policy proceeds on the basis that the divorce decree was a Qualified Domestic Relations Order (QDRO) under ERISA. The district court agreed with the daughter, finding that the divorce decree qualified as a QDRO because it substantially complied with ERISA’s QDRO requirements. The district court explained in its decision that where a divorce decree qualifies as a QDRO, it can assign the right to a participant’s benefits under a welfare plan such as an employer-provided life insurance policy. Therefore, because the divorce decree in this case qualified as a QDRO, the daughter was entitled to the full policy proceeds even though the participant named his second wife as the primary beneficiary. (Metropolitan Life Insurance Co. v. Darkow, N.D. Ohio 2010)