Deborah Baldwin v. UPMC, et al

The biological mother of three children lived with the children and their adoptive mother and named the adoptive mother as beneficiary on one of her life insurance policies through her employer. She did not name beneficiaries on other policies and, after she died, the insurers rejected claims on behalf of the children. The district court dismissed claims under the Employee Income Security Act (ERISA), 29 U.S.C. 1001, which lists children as default beneficiaries. The Third Circuit vacated and remanded. ERISA grants standing to participants and beneficiaries; whether the term "children," as used in the insurance contracts, includes biological children who have been adopted by a non-participant is ambiguous. There was evidence of the insured's intent to benefit the children, sufficient to create a colorable claim adequate to support standing.