RECENT LEGAL ISSUES AND DECISIONS
SPRING 2011 CONFERENCE
This summary is presented to provide a general reference to recent legal decisions of interest to Michigan public retirement and healthcare plans.
McKnight v. General Retirement System of the City of Detroit
Michigan Court of Appeals – Decided November 16, 2010 2010 Mich. App. LEXIS 2165
A member of the Retirement System named his wife as his primary survivor beneficiary and his mother as his contingent survivor beneficiary on membership enrollment forms. The member subsequently divorced his wife and died without amending his beneficiary forms. When his mother sought payment of his death benefit and annuity, the Retirement System indicated that it would pay the benefits to the deceased member’s estate. The mother sued the Retirement System seeking a declaratory judgment for payment of the annuity and death benefit. The Court of Appeals awarded the mother payment of benefits as the member’s only eligible beneficiary who was living at the time of his death. The Court reasoned that the mother qualified in line of succession because the member’s former wife no longer met the qualification requirements as a result of the divorce.