DOVER, Del. (AP) — The ex-husband of a woman who was slain in a murder-suicide in Pennsylvania stemming from a love triangle must relinquish proceeds he received from her individual life insurance policies, a Delaware judge ruled Thursday.
But Vice Chancellor Sam Glasscock III also ruled that Meredith Sullivan’s ex-husband, Luke Chapman, is entitled to keep the proceeds from her University of Delaware group life insurance policy.
The rulings uphold the findings in a report issued in February by a Chancery Court officer. That report was handed down exactly three years to the day that Chapman filed for divorce from Sullivan.
The dispute over the insurance policies involved conflicting state laws and came in a case of first impression, meaning it involved a novel issue that had never been addressed previously by a Delaware court.
Sullivan was killed at her Pennsylvania residence in April 2018, two weeks after Delaware’s Family Court entered the divorce decree. The wife of a man with whom Sullivan was having an affair broke into her home, waited for her to arrive, then fatally shot Sullivan before killing herself. Sullivan, 33, was killed just days after taking a job as an assistant vice president at Villanova University. She had previously been a senior director for marketing at the University of Delaware.
Following Sullivan’s death, Chapman received the proceeds of two individual life insurance policies, for which he was the sole beneficiary. He also received insurance proceeds as the primary beneficiary on Sullivan’s group life insurance policy.
Sullivan’s mother and siblings argued that Chapman was not entitled to the insurance proceeds, even though the policies were issued in Delaware, because she had moved to Pennsylvania shortly before her death.
Under Pennsylvania’s “revocation upon divorce” law, the former spouse of a life insurance policy holder is deemed to have “predeceased” the policy holder for beneficiary purposes and is not entitled to any proceeds. The law is based on the presumption that a policy holder who names a spouse as beneficiary, then is divorced and dies without having changed the beneficiary designation, nonetheless intended to remove the ex-spouse as a beneficiary.
Delaware law also has a “revocation upon divorce” provision but, unlike Pennsylvania’s law, which applies both to wills and insurance policies, Delaware’s law applies only to wills.
Chapman argued in a court petition that because the divorce decree was issued in Delaware, and because the insurance policies were issued in Delaware, Delaware law governs the disposition of the insurance proceeds and he is the proper recipient.
Glassock agreed with the conclusion by Master in Chancery Patricia Griffin that, because Sullivan was living in Pennsylvania at the time of her death, Pennsylvania has a stronger policy interest in ensuring that its public policy on automatic revocation of beneficiary designations is implemented.
“Pennsylvania surely has more interest in the vindication of the intent of its residents than Delaware has over non-residents,” Glasscock wrote.
Regarding the group insurance policy, however, Glassock noted that the contracting parties were not Sullivan and her insurer, as was the case with the individual policies, but were the university — “obviously a Delaware resident” — and its insurer. Chapman, as primary beneficiary, is thus entitled under Delaware law to the proceeds of the group life insurance policy, the judge determined.