Court upholds Uniform Electronic Transactions Act application to Beneficiary designation

Julie Ann Zulkiewski was forced to sue the American General LIfe Insurance Company and her husband's parents to collect the life insurance proceeds payable after her husband committed suicide.  The husband, a doctor, had purchased a $250,000.00 policy during his first marriage and listed his parents as contingent beneficiaries.  Later he apparently changed the beneficiary status to make his second wife primary.  The parents challenged this change, contending that Julie Ann could not prove that her husband was actually the person who effected it. 

American General representatives provided proof that the insured needed to enter the policy number, his social security number, his mother's maiden name and an e-mail address in order to change beneficiaries electronically.  Taking into account this evidence the trial judge ruled that Julie Ann's husband was the person who changed beneficiaries.  His parents appealed, but the Court of Appeals upheld the decision of the lower court.