Background:

• Dispute over $113,314.86 from three life insurance policies of the deceased, Douglas Ross.
• Proceeds paid to his mother, Bonnie Ross, as the designated beneficiary.
• Carolyn Ross, the deceased's wife, seeks constructive trust and alleges unjust enrichment.

Plaintiff's Claims:

• Carolyn claims she was the intended beneficiary and that Bonnie was unjustly enriched.
• Seeks declaration of constructive trust, payment of proceeds, pre-judgment interest, and costs.

Defendant's Position:

• Bonnie Ross argues she holds legal and beneficial title as the named beneficiary and denies unjust enrichment, asserting juristic reasons for her entitlement.

Facts:

• Douglas Ross died in 2020 in an ATV accident.
• He named his mother as the sole beneficiary of the disputed policies, having previously included both parents.
• Carolyn was the beneficiary of a separate 2011 policy.

Legal Analysis:

• Court found no clear evidence Douglas intended to change the beneficiary to Carolyn.
• Applied the three-part test for unjust enrichment:
  1. Enrichment of the defendant.
  2. Corresponding deprivation of the plaintiff.
  3. Lack of juristic reason.
• Determined Bonnie was enriched but there was no corresponding deprivation of Carolyn without juristic reason.

Outcome:

• Carolyn Ross' application dismissed.
• Bonnie Ross entitled to costs at Scale B.

This case highlights the importance of explicit beneficiary designations in insurance policies and the challenge of contesting them without clear evidence of the insured's intent.