A woman filed suit against the Teacher Retirement System of Texas after it denied her request to be recognized as the beneficiary of her former husband’s death benefits. The district court held that she should not be recognized as the beneficiary and she appealed to the Third Court of Appeals.

The woman had been designated by her husband in 1977 as the primary beneficiary of his death benefits payable by TRS. The couple divorced in 2008. In the divorce decree, they agreed that she would be “divested of all right, title, interest and claim” to his TRS benefits. At no time after the divorce did the former husband send a new beneficiary designation form to TRS. In 2012, he submitted a form to TRS titled “Request for Estimate of Retirement Benefits.” In response to the question “Whom do you plan to name as beneficiary at retirement?” He wrote “undecided.” He passed away in 2015.

After the former husband’s death, TRS sent letters to the former wife and the executor of the former husband’s estate (his brother). The letter indicated that the former wife was designated as the primary beneficiary of the account and stated that under applicable law, receipt by TRS of a certified copy of a divorce decree between a TRS member or annuitant and a designated beneficiary revokes any designation of the former spouse as a beneficiary of the death benefits. This law applies if the designation was effective before the date of divorce. The letter then went on to request the parties to forward a copy of the divorce decree to TRS. Both the former wife and the executor sent a copy of the divorce decree to TRS. TRS then made a determination that the former wife was not entitled to death benefits because the divorce decree revoked her designation as beneficiary. She appealed, arguing that she would not have sent TRS a copy of the divorce decree had she known that it would have resulted in a loss of death benefits to her and that TRS should have notified her that this would occur.

The court of appeals upheld the determination that the former wife was not entitled to death benefits. There was no dispute that: 1. the wife was the designated beneficiary, 2. she was his spouse at the time of the designation, 3. the parties divorced after she had been designated as beneficiary, and 4. TRS received a certified copy of the divorce decree before any part of the death benefits had been paid to any beneficiary. In reaching this conclusion, the court noted that TRS had also received a copy of the divorce decree from the executor of the estate.