The First Circuit Court of Appeals found that a postal service employee had validly designated his former wife and their children as beneficiaries of his life insurance policy because the designation form was in writing, signed, witnessed, and received by the proper office prior to his death as required by statute; his failure to complete other parts of the form not required by statute did not invalidate it. Hebert v. Donahue, 167 F.4th 1 (1st Cir. 2026 Feb. 5, 2026).
Prior to his death, Gary Hebert, who worked at the United States Postal Service, was married to Tiffany Donahue-Hebert. Shortly before he died, however, Gary executed a designation of beneficiary form naming his ex-wife Kathleen and his sons, Trevor and Zachery (collectively, the Heberts), as beneficiaries of his Federal Employees’ Group Life Insurance (FEGLI) policy. A friend and another USPS employee witnessed Gary sign the beneficiary designation form, and they both signed on the witness signature lines. Gary did not complete the part of the designation form that included spaces for the preparer’s name and address and whether the preparer is the insured or an assignee, nor did he check certain boxes the form directed him to check.
Kathleen sent the designation form to the appropriate human resources center, but the center returned it unprocessed because of the incomplete section and directed Gary to complete the missing information. On February 14, 2017, Gary asked Kathleen to complete the section. He died on February 15, 2017. Although Kathleen faxed the completed form to the human resources center on February 16, 2017, the center rejected the form because it was received after Gary’s death.
In July 2018, the Heberts brought a suit against Tiffany, the federal Office of Personnel Management, and the life insurance company seeking a declaration that the beneficiary designation form was valid. While the litigation was pending, Tiffany died, and her daughter and personal representative, Karissa, proceeded in her stead. The federal district court granted summary judgment in favor of the Heberts, adopting an earlier memorandum in which it had concluded that Gary’s beneficiary designation was valid. Karissa, as personal representative, appealed, asserting that both beneficiary designation forms were invalid and that Gary was not mentally competent when he signed the first form.
In a de novo review of the district court’s judgment, the First Circuit Court of Appeals noted that the Federal Employees’ Group Life Insurance Act (FEGLIA), 5 U.S.C. § 8705(a), provides that life insurance proceeds should be paid to the beneficiaries designated by the employee in a signed and witnessed writing received before death in the employing office; however, if there is no designated beneficiary, the proceeds will be paid to the employee’s widow or widower. The court found that, in previous cases addressing FEGLIA, courts had uniformly held that beneficiary designation forms that were signed and witnessed were valid despite other irregularities.
Although Karissa argued that regulations implementing FEGLIA required all parts of the beneficiary form to be completed for it to be considered valid, the court found that the regulatory language, read in context and with a view to its place in the statutory scheme, reiterated the statutory language that the designation form was complete when it was in writing, signed, and witnessed by two people. Consequently, despite the omitted information, Gary had validly designated the Heberts as beneficiaries of his life insurance policy. In addition, the court held that the relevant regulations, read in conjunction with FEGLIA, required only that the designation form be received in the employing office: Thus, the human resource center’s rejection and return of Gary’s designation form did not invalidate it.
Further, because Karissa had failed to present any medical evidence supporting her argument that Gary was mentally incapacitated when he signed the beneficiary designation form, the court concluded that she failed to carry her burden of proof under both Massachusetts and federal law.
Accordingly, the court affirmed the district court’s judgment in favor of the Heberts.
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