Plaintiff Kristopher Towles, the son of a deceased participant of a life insurance plan, challenged the plan's decision to pay the life insurance proceeds to the deceased's husband, contending that the beneficiary form replacing him with the deceased husband had been forged. After five attempts to state a claim, the district court dismissed the complaint for failure to plead a viable claim. The Tenth Circuit affirmed and further noted that Kristopher's allegations that the forms were forged failed to state a claim under ERISA because a plan administrator has no duty to inquire into the authenticity of the forms if it had "no reason to suspect that anything was amiss." The case is Yarbary v. Martin, Pringle, Oliver, Wallace & Bauer, LLP, No. 14-3101, 2014 WL 6679881 (10th Cir. Nov. 24, 2014).
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