In Prudential Ins. Co. v. Durante, the El Paso Court of Appeals confirmed that a widow had standing to bring a claim for policy benefits under the Texas doctrine of substantial compliance. Her husband attempted to make a beneficiary designation change and name her as a 50% beneficiary. However, the insurance company rejected the attempted beneficiary change because it deemed his designation of contingent beneficiaries ambiguous. The insurance company notified the husband in writing that he needed to correct the form, but he died before making the corrections.
The widow made a claim to the benefits and the insurance company filed an interpleader. The trial court found that the widow was indeed entitled to 50% of the benefits. The Court of Appeals affirmed that decision, finding that the husband had substantially complied with the insurance company's procedures for making a beneficiary change. It was quite clear that the husband intended for his wife to receive those benefits, even if his designation of contingent beneficiaries was not clear.