Beltway Paving Company v. Pruco Life Insurance Company - Insurance Beneficiary Dispute

UNPUBLISHED UNITED STATES COURT OF AP PEALS FOR THE FOURTH CIRCUIT No. 25- 1288 BELTWAY PAV ING COMPANY, INC., Plaintiff - Appellant, v. PRUCO LIFE INSURANCE COMPANY; LISA M. MOORE, Personal Representative of the Estate of Timothy S. Moore, Defendant s - Appell ees. Appeal from the United States District C ourt for the District of Mary land, at Greenbelt. Brendan A. Hurson, District Judge. (8:21 - cv - 0 0264 - BAH) Argued: December 11, 2025 D ecided: February 27, 2026 Before NIEMEYER, WYNN, and BENJAMIN, Circuit Judges. Affirmed by unpublished opinion. Ju dge Niemeyer wrote the opinion, in w hich Judge Wynn and J udge Benj amin joine d. ARGUED: Eden Joanna Brown Gaines, BROWN GAINES LLC, Washington, D.C., for Appellant. Brian Patrick Donnelly, W ERTHER & MILLS, LLC, Rockville, Maryland; Christina M. Carroll, DENTONS US LLP, Washington, D.C., for Appellees. ON BRIEF: Tony K. Lu, DENTONS US LLP, Boston, M assachusetts, for Appellee Pruco Life Insurance Company. Unpublished opinions are not binding p recedent in this circuit.

2 NIEMEYER, Circuit Judge: This case arises out of a disagreemen t over the rightful beneficiary of a $1 million life insurance policy between the beneficiary design ated in the policy and Beltway Paving Company, Inc., a Maryland corporation, whom the policy’s owner may have t hought abo ut naming as beneficiary but never appeared to make that decision, nor took any ste ps to effect it. Pruco Life Insurance Company (“Pruco”) issued a life insurance po licy in 2017 to Timothy Moore, who designated his business associate, Michael Williams, as the sole beneficiary. Moore and Williams were bu siness partners in Beltway Paving, an d the company paid the premiums fo r the policy. Under th e terms of the policy, if Williams predeceased Moore, the death benefit would be paid to Moore’s estate. Williams, the beneficiary of the policy, unexpectedly died in February 2020. Moore then, along with William s ’s daughter, Christine Willi ams - Murphy, met with Moore’s insurance agents, Craig Schubert and Denice Warfield, in March 2020, to discuss lif e insurance options related to at least two policies that the agents had issued. In add ition to the 2017 policy issued to Moore, Pruco h ad also issued a $1 million life insurance policy to Beltway Paving in 2015 on Moo re ’s life, as a key person in the busin ess. In the meeting, Sc hubert and Warfield exp lained the policies and reviewed various options. According to both Schubert and Warfield, they pointed out th at Williams was the sole beneficiary of the 2017 policy and that if they did not change the beneficiary, the death b enefit would be payable to Moore’s estate upon his death. T estif yi ng about the meeting, the agents said “at no time during the March 5, 2020 meeting (or at any time before or after that) did either

3 Moore or Williams - Murphy ever question the fact th at Williams was the sole b eneficiary of the 2017 policy, much less indicate that he w as not the intended beneficiary or that he had been named as the beneficiary by mistake o r through error.” Williams - Murphy did not contradict the insurance agents’ testimony, having no recollecti on of wh ether the m eeting even took place. Shortly after the meeting, insurance agent Schubert sent Moore and Williams - Murphy an email summarizing th e March 5 meeting and stating that “[f]rom our conversation Tim [Moore] and Christine [Williams - Murphy] wanted t o have $500k go to their spouses directly and for Beltway to have $2m for Tim and $3m for Christine as part of the [stock - related ] Buy/Sell agreement. Also having po licies with cash value to help create a fund for buying out shares du e to disability, retirement or voluntary separation.” In a table listing Moore’s po licies, agent Schubert included the 2017 po licy, “recommend[ing] change” for th e policy to “[c]on vert to Index Universal Life; change owner and beneficiary to Beltway.” Schubert n ever receive d a response to this email, and W illiams - Murphy testified she did not remember speaking with Schubert after the email. Ag ent Warfield sent additional follow - up emails regarding the 2017 po licy on September 9 and September 29, 2020, but again neither Moore nor Williams - Murphy respo nded. According to Schube rt and Warfield, “[a]t no time . . . di d Moore or Williams - Murphy authorize or instruct . . . [Pru co] to proceed with a beneficiary change.” A few months later, in November 2020, Moore died, and, fo llowing the terms of the 2017 p olicy, Pruco paid the death benefit of $1 million to Moore’s e state.

4 Beltway Paving, now controlled b y Williams - Murphy as the majority shareh older and its CEO, commenced this action contending that the benefits of the 2017 policy should have been paid to Beltway Paving. It sough t a declaratory judgment that Beltway Paving wa s the owner and beneficiary of the 2017 policy, and it mad e a claim against Moore’s estate to return the proceeds under a theory of unjust enrichment. The district court granted summary judgment to Pruco and Moore’s estate, concluding that Beltway Paving had failed to produce sufficient evidence to su pport its claim that the company was the intended beneficiary of the 2017 poli cy or that Moore had intended a nd taken any steps to change the beneficiary to name Beltway Paving. From the district court’s judgment, Beltway Pav ing appealed. This appeal presents the straightfo rward question of whether Beltway Paving provided sufficient evidence to show that it was the intended beneficiary of the 2017 policy and that Moore’s estate was thereby unjustly enriched when it received th e policy’s $1 million benefit upon Moo re’s death. We agree with the district court that the evidence was insufficient to send this case to the ju ry. First, there was no evidence that Moore accidently o r by error named William s as the beneficiary in the 2017 policy. To the contrary, both of the insurance agents testified that the policy accurately represented both Moore and Williams’s intentions. Indeed, that fact was highlighted by the fact that Beltwa y Paving had taken out the 2015 polic y on Moore’s life as a “K ey P erson,” naming Beltway P aving as the beneficiary, thus distingui shing t h e 2015 policy from the 2017 policy. Second, there was also insuf ficient evidence to support any find ing that Moore or Williams intend ed that Beltway Paving be

5 the beneficiary of the 2017 policy. Finally, there was no evidence after Williams’ s d eath to indicate that Beltway Paving was the new intended beneficiary of the policy. While the insurance agents, Schubert and Warfield had a meeting to discuss potential changes to the policy, indeed recommend ing a change, the evidence shows, without d ispute, that neither Moore nor Williams - Murphy ever took any steps to change th e beneficiary of the 2017 policy or even to indicate an intent to make the change. See Du rst v. Durst, 232 Md. 311, 317 (1963) (noting that an insured “must comply with the provisions of a policy regulating a change of beneficiaries” for that change to be effective (citing Daly v. Da ly, 138 Md. 155 (1921))). Crucially, fo r a change of beneficiary to b e effective on an equitable basis, despite the policy owner ’s failure to actually e ffe ct the change, t he policy owner must have “do[ne] all in his power to effectuate the chang e.” Id. (collecting cases); see also Lingham v. Harmon, 502 F. Supp. 302, 306 (D. Md. 1980) (“The great weight of authority in this country appears to endorse th e general principle that the insured, in order for the chan ge of beneficiary to be effective, m ust have determined to chang e the beneficiary and must ha ve done everything to the best of his ability therea fter to effect the change ”) (collecting cases) (emphasis added); Reid v. Durbo raw, 272 F. 99, 101 (4th Cir. 1921) (courts have “no power” to change the beneficiary in a valid insurance contract unless the insured “has done all that he could to comply with the conditions, and has been prevented by circumstances beyond his control from meeting the requirements”). Here, Beltway Paving has provided no evi dence that Moore actually intended o r decided to change the beneficiary of th e 2017 policy to Beltway P aving, or that he took specific steps to make the change — let alone did “all in his power to effectuate the

6 change. ” Durst, 232 M d. at 317. While agen ts S c hubert and Warfield offered to make cha nges, indeed recommending some, neither Moore nor Williams - Murphy communicated further, taking no steps to indicate that they wanted a change or d irecting that a change be made. Absent such evidence, Pruco prop erly paid the death benefit of the 2017 po licy to Moore’s estate, as required by the policy itself. The judgment of the district court is accord ingly AFFIRMED.