## Facts

- In 1961, an insurer issued a $100,000 life insurance policy insuring Ella B. Ryder; the policy permitted beneficiary changes by filing a written request “on a form satisfactory to the company,” effective only when recorded by the insurer.
- After Ryder’s husband died in 1973, Ryder became the policy owner with authority to change beneficiaries.
- Ryder sought to remove her nephew as beneficiary and, in 1978, wrote to the insurer requesting a beneficiary-change form naming her estate; there was no evidence the insurer sent the requested form then.
- In 1979, Ryder signed and had witnessed a letter identifying the policy and directing that the beneficiary be changed to her estate; the insurer received it.
- The insurer responded by sending its own change-of-beneficiary form and stated it would not change the beneficiary unless the form was completed and returned; Ryder never returned the form but continued paying premiums.
- After Ryder’s death, her executor (Engelman) claimed the proceeds for the estate; the insurer refused, asserting Ryder had not complied with the “form satisfactory to the company” requirement, while admitting Ryder’s intent to change beneficiaries was clear and that the 1979 letter satisfied the insurer’s formalities other than use of its form.

## Issues

1. Whether a life-insurance beneficiary change clause requiring a written request “on a form satisfactory to the company” and insurer recording allows an effective change by substantial compliance rather than strict compliance.
2. Whether the insured’s 1979 letter, together with the insurer’s failure to provide and process requested forms, constituted substantial compliance making the estate the beneficiary.

## Decision

- The Connecticut Supreme Court reversed the judgment for the insurer.
- The court adopted the substantial compliance doctrine for life-insurance beneficiary changes in Connecticut.
- Applying that doctrine, the court held Ryder substantially complied with the policy’s change-of-beneficiary requirements and effectively changed the beneficiary to her estate.
- The court concluded the insurer breached the contract by refusing to pay the proceeds to the estate.

## Legal Principles

- A beneficiary change may be effective without literal compliance with policy procedures when the insured clearly intends the change and has done all that is reasonably possible under the circumstances to carry it out.
- When only ministerial acts by the insurer remain, an insurer may not defeat a clearly intended change by relying on technical procedural requirements, particularly where the insurer’s inaction contributed to noncompliance.
- Ambiguity or lack of definition in policy phrases such as “form satisfactory to the company” supports construing change provisions to prevent forfeiture where the insurer has notice and is not prejudiced.

## Conclusion

Connecticut recognized substantial compliance as the governing standard for life-insurance beneficiary changes and held that Ryder’s clear written direction to name her estate as beneficiary was effective despite her failure to return the insurer’s preferred form, making the estate entitled to the policy proceeds.


Engelman v. Conn. Gen. Life Ins. Co., 690 A.2d 882 (Conn. 1997)