Stephenson v. Spiegle
New Jersey Superior Court, Appellate Division
58 A.3d 1228 (2013)
Jack Murray had his will drafted with help from attorney William Spiegle (defendant), naming certain family members as beneficiaries. Less than two months later, without Spiegle's knowledge, Murray opened a bank account and named Spiegle -- with whom he had only an attorney-client relationship, nothing personal -- as its beneficiary. When Murray died, the account held about a third of his estate. Dan Stephenson (plaintiff), the estate's executor, sued after Spiegle claimed the account funds. The trial court found the only plausible explanation was that Murray meant to have Spiegle hold the money so it could eventually be added to the will, meaning Murray had simply made a mistake in his beneficiary designation, and ordered the funds returned to the estate. Spiegle appealed.
Whether equity permits rescinding a beneficiary designation on a financial account when the account holder made an unexplained, unilateral mistake in naming that beneficiary.