## Facts

- Robert Vasconi designated his then-wife, Leah Vasconi Wolf, as beneficiary of his employer-provided group life insurance policy issued by Guardian.
- Robert and Leah divorced in 1985 and executed a property-settlement agreement (PSA) containing a broad mutual release of each party’s interests and claims in the other’s estate at death.
- The PSA did not specifically mention the group life policy or any beneficiary change.
- Robert died in 1986 without completing Guardian’s change-of-beneficiary procedures; Leah remained the beneficiary of record.
- The estate’s administrator claimed (1) Robert intended to remove Leah but failed to complete the required forms and (2) Leah relinquished any right to the proceeds through the PSA.
- Guardian faced competing claims and paid the proceeds to Leah after a lower-court judgment in her favor.

## Issues

1. Whether a divorce PSA containing a general mutual release can extinguish an ex-spouse’s right to life-insurance proceeds despite the insured’s failure to execute a formal beneficiary change under the policy.
2. Whether a court may consider extrinsic evidence of the decedent’s probable intent to determine entitlement to the proceeds in the divorce context.

## Decision

- The New Jersey Supreme Court reversed the Appellate Division and trial court.
- The Court rejected a rigid rule that the beneficiary designation automatically controls after divorce whenever the insured did not comply with the policy’s change procedures.
- The Court held that a PSA and the parties’ probable intent may, depending on proof, defeat an ex-spouse’s claim to policy proceeds.
- The case was remanded for a factual hearing to construe the PSA and determine the decedent’s probable intent, including consideration of extrinsic evidence.

## Legal Principles

- In divorce-related disputes, entitlement to life-insurance proceeds is not determined solely by the named beneficiary when a later PSA may have altered the parties’ rights.
- Property-settlement agreements are construed as contracts in light of the circumstances and the parties’ probable intent; extrinsic evidence may be admitted to determine intended scope.
- A broadly worded mutual release of rights in the other party’s estate can encompass life-insurance benefits, even if the policy is not specifically identified, depending on the agreement’s meaning and context.
- The traditional “strict/substantial compliance” doctrine for changing beneficiaries under an insurance contract is not the exclusive framework when a divorce judgment and PSA supply a separate contractual basis to alter rights.

## Conclusion

The court held that a divorce settlement’s general release may waive an ex-spouse’s right to life-insurance proceeds and that courts may examine the PSA and extrinsic evidence of probable intent rather than mechanically enforcing the beneficiary designation; the matter was remanded for fact-finding.


Vasconi v. Guardian Life Ins. Co. of Am., 124 N.J. 338, 590 A.2d 1161 (1991)