Family Law Blog

Characterization of Life Insurance Policies

Some life insurance policies have  cash value that can be considered in a divorce.  Types of life insurance policies with cash value include whole life, universal life, variable life, and indexed life insurance.  Click here for an article that explains these types of insurance.  A term life insurance policy may have an owner, but it does not have surrender value that would go on a property division spreadsheet.

Life insurance is separate property or community property depending on when the policy was first purchased, just like a house is.  The “inception of title” rule applies to life insurance policies, according to cases such as Rolls v. Rolls, No. 03-14-00435-CV  (Tex. App.-Austin Jan. 14, 2016, no pet.) (mem. op.).  In that case, the husband (Otis) bought a cash life insurance policy in 1988, married in 2002 and divorced in 2014.  The Austin Court of Appeals in this case held:

Insurance policies are governed by the inception-of-title doctrine, meaning the separate or community character of a policy is determined by the time and circumstances of its acquisition.  Otis’s insurance policy, having been acquired before the marriage, is his separate property. At most, Susan could only seek a portion of the reimbursement the community estate might be entitled to for premiums paid during the marriage.

(citations omitted).

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