Sobel v. Sobel

Summary

The Florida Fourth District Court of Appeal considered whether a 2013 IRA beneficiary designation controlled the distribution of the decedent's IRA. The court held that the designation never became effective because the IRA agreement required receipt and acceptance by UBS, and there was no evidence that UBS received or accepted it. The court reversed the summary judgment and remanded for entry of judgment in favor of the appellants.

Holdings

1. The appellants had standing to challenge the distribution of the IRA proceeds.
2. The 2013 beneficiary designation was ineffective because the Custodial Agreement required the form to be received and accepted by UBS, and there was no record evidence of either receipt or acceptance.
3. The substantial-compliance doctrine cannot excuse failure to comply with a material contractual requirement that UBS receive and accept the beneficiary designation.

Questions Presented

1. Whether the appellants had standing to challenge the distribution of the IRA proceeds.
2. Whether the 2013 beneficiary designation was effective under the IRA Custodial Agreement when there was no evidence that UBS received or accepted it.
3. Whether the substantial-compliance doctrine could override the Custodial Agreement's requirement that UBS accept a beneficiary designation form.

Disposition

reversed_and_remanded