Hertzske v. Snyder, 2017 UT 4 (Jan. 18, 2017)

This appeal arose out of a dispute over the proceeds of a life insurance policy.  Before his death, the policy owner disinherited and divorced his spouse, but he failed to change the beneficiary designation.  The Supreme Court held that, in the absence of express terms that reference divorce in a life insurance policy, there is a statutory presumption that a beneficiary designation of a former spouse is revoked upon divorce.  The presumption may be rebutted by the express incorporation of language from Utah Code § 30-3-5(1)(e) in the divorce decree.