Mayo v. Hartford Life Insurance Company

NOTE: the source document's Facts, Issue, and Holding sections under this case caption describe a company-owned life-insurance (COLI) dispute involving Wal-Mart Stores, Inc. (Walmart), not a dispute directly involving a party named 'Mayo' or 'Hartford Life Insurance Company'; this entry preserves the source text's own party labels rather than substituting the caption names, and is flagged here for manual review. As described in the source: Walmart established a COLI program insuring the lives of its employees, with Walmart as beneficiary; employees were covered unless they opted out of a related special-death-benefits program. Walmart discontinued the COLI program in 1998. Douglas Sims, a Walmart employee from 1987 until his death in 1998, was insured under a COLI policy. Sims's estate (plaintiff) sued Walmart (defendant), claiming the policy violated the Texas insurable-interest doctrine, and sought a declaratory judgment, a constructive trust, and disgorgement of the COLI proceeds. The district court granted the estate partial summary judgment, holding Walmart lacked an insurable interest in the lives of its regular employees, and Walmart appealed.