Marriage of Spengler

Barbara Spengler (plaintiff) married Daniel Spengler in 1967. Daniel's employer, Mid-Valley Dairy, provided a group term-life policy that let him renew coverage without a physical exam or proof of insurability, though no contract guaranteed that right. After Daniel was diagnosed with prostate cancer in 1982, a condition that would have made him otherwise uninsurable, he and Barbara divorced in 1986. Daniel kept renewing the Mid-Valley policy, later married Rose Spengler (defendant) in 1989 and named her beneficiary, and died a few months after that marriage. Rose collected the $100,000 death benefit, and Barbara sued for half, claiming the policy remained partly community property from her marriage to Daniel. The trial court awarded Barbara half, and Rose appealed.