Decedent Substantially Complied with Policy to Retain Former Spouse as Beneficiary

Because 20 Pa.C.S. § 6111.2(b)(4) does not require that a post-divorce “designation of a former spouse as a beneficiary” be in writing, and because the decedent “substantially complied” with the life insurance policy provisions for beneficiary designations by orally advising the insurance agent that he was divorced but wished his former spouse to remain the beneficiary of the policy, and it was reasonable for him to take no further action after the agent advised him (incorrectly) that no additional written documentation was needed because the former spouse was already designated as the beneficiary, the proceeds of the policy were properly payable to the former spouse. State Farm Insurance Company v. Kitko, ___ A.3d ___, 2020 PA Super 253 (10/20/2020).

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