Widow's Release Of Claims Against Deceased Husband's Estate Did Not Extinguish Her Right To His Pension Account

It makes me sad to learn when heirs fight over a decedent's assets, especially when it involves a widow's surviving spouse pension benefits, as occurred in Goins v. Tona L. Goins & Nat'l Elec. Annuity Plan, No. 16-cv-01281, 2017 U.S. Dist. LEXIS 71387 (S.D. Ill. May 10, 2017).

In Goins, Robert Goins passed away and was survived by his wife Tona Goins and two adult sons who were Tona's step sons. Sometime after Robert's death, a dispute arose between Tona and the step sons as to who would pay Robert's funeral expenses. Ultimately, the step sons agreed to pay Robert's funeral expenses in exchange for Tona signing a Release which stated that she was releasing any further interest she might have in Robert's estate.

After Tona signed the Release, it was learned that Robert had a 401(k) pension account valued at approximately $69,552.13. As Robert's surviving spouse, Tona claimed that she was entitled to the pension account. Robert's step sons disagreed, insisting that they were entitled to the pension account on the ground that it was part of Robert's estate and that Tona had released any interest she might have in Robert's estate. In the ensuing litigation, Tona filed a letter with the court, advising that was living on $750/month in disability benefits while Robert's step sons were "wealthy" and "never had to want for anything," and that she needed the funds from the pension account to pay her medical expenses.

In ruling for Tona, the district court did not comment on her letter. Rather, the district court reasoned that (i) Robert's 401(k) plan was governed by ERISA [the Employee Retirement Income Security Act, which governs most private-sector pension plans]; (ii) under ERISA, a person's entitlement to pension benefits is based on the terms of the plan; (iii) Robert's 401(k) plan states that if the participant is married at the time of the participant's death, the account balance must be paid to the participant's surviving spouse or to a designated beneficiary approved by the spouse; (iv) Tona was the surviving spouse and Robert had not designated a different beneficiary; and (v) therefore, Tona was the beneficiary of Robert's 401(k) pension account.

While the district court clearly reached the correct result, what troubled me about this case was that the decedent's sons were trying to divest their financially-strapped and widowed step mother out of over $69,000 in surviving spouse pension benefits simply because they had paid their father's funeral expenses. Most funerals do not cost anywhere near $69,000. The words GREED and LACK OF COMPASSION seem apposite here.

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