FEGLIA “Receipt” Defined: Delivery to Employing-Office Personnel Suffices; No Indicia-of-Receipt or File-Presence Requirement

Case: Metropolitan v. Vasquez, No. 24-11024 (5th Cir. Oct. 1, 2025) (per curiam) (unpublished)

Court: United States Court of Appeals for the Fifth Circuit

Panel: Chief Judge Elrod, and Judges Clement and Haynes

Introduction

In Metropolitan v. Vasquez, the Fifth Circuit resolved a recurring problem in Federal Employees’ Group Life Insurance (FEGLI) disputes: what it means for a beneficiary designation to be “received” by the employing office under 5 U.S.C. § 8705(a). After the death of federal employee John Mario Vasquez, Jr., both his mother (Elvira S. Avelar) and his widow (Rebecca D. Vasquez) claimed FEGLI proceeds. The employer’s file contained only a 2007 designation naming the mother; the widow produced a later 2013 signed-and-witnessed designation naming herself and offered testimony that the insured delivered the form to Human Resources (HR). The district court granted summary judgment to the mother, holding that “receipt” required “indicia of receipt” (e.g., an agency stamp or signature) or the form’s presence in the personnel file.

The Fifth Circuit reversed. Drawing on analogous Servicemembers’ Group Life Insurance Act (SGLIA) precedent and FEGLIA’s text and regulations, the court held that a designation is “received” when the insured hands the form to an appropriate person at the employing office; neither a date-stamp nor the form’s presence in the personnel file is required by statute or regulation. Because witness testimony created a genuine dispute of material fact on receipt, summary judgment for the mother was improper. The court remanded for trial, leaving one factual question open: whether delivery to the HR official at the Dallas facility satisfied the “employing office” requirement.

Summary of the Opinion

• Issue: Does FEGLIA’s “received before death in the employing office” language (5 U.S.C. § 8705(a)) require indicia such as a receipt stamp or placement in the personnel file? What evidence suffices at summary judgment to establish “receipt”?
• Holding: No. “Received” does not require an agency stamp, written acknowledgment, or file presence. A designation is “received” when the insured delivers it to an appropriate person at the employing office.
• Key Authority: Coomer v. United States (5th Cir. 1973) (interpreting analogous SGLIA provision) establishes that “receipt” occurs when the insured hands the designation to the person responsible for receiving and maintaining such forms; subsequent mishandling cannot defeat a valid designation.
• Evidence: The widow offered a properly signed and witnessed 2013 designation and a declaration from the insured’s supervisor who personally observed the insured deliver the form to HR. That witness evidence creates a triable issue of fact.
• Disposition: Reversed the grant of summary judgment to the mother and remanded for trial. The district court must address on remand whether handing the form to the on-site HR official constituted delivery to the “employing office.”
• Standards Applied: De novo review of summary judgment and statutory interpretation; credibility determinations are inappropriate at summary judgment.

Detailed Analysis

Precedents and Authorities Cited

• FEGLIA Text: 5 U.S.C. § 8705(a) provides that proceeds are payable “to the beneficiary or beneficiaries designated by the employee in a signed and witnessed writing received before death in the employing office.” The statute uses “received,” but does not define it or require any formal agency acknowledgment.
• FEGLI Regulations: 5 C.F.R. § 870.802(b) (2025) states the employing office “must receive the designation before the death of the insured” and allows submission “via appropriate methods approved by the employing office.” There is no regulatory requirement that the designation be stamped, signed by HR, or preserved in the personnel file to be valid.
• Coomer v. United States, 471 F.2d 1 (5th Cir. 1973): Interpreting SGLIA’s near-identical “received” requirement, the court held that “whatever receipt means, it certainly occurs” when the servicemember hands the designation to the person the service has put in charge of receiving and maintaining such forms. The later loss or misfiling of the form does not defeat the insured’s duly expressed intent.
• Hillman v. Maretta, 569 U.S. 483 (2013): Describes FEGLIA’s overall structure and order of precedence, and highlights its similarity to SGLIA (supporting the use of SGLIA precedents in construing FEGLIA).
• Stribling v. United States, 419 F.2d 1350 (8th Cir. 1969): Notes SGLIA’s structure was modeled after FEGLIA, underscoring the interpretive cross-pollination between the statutes.
• BNSF Ry. Co. v. United States, 775 F.3d 743, 756 (5th Cir. 2015): “Similar language in similar statutes should be interpreted similarly.” This canon justified relying on Coomer’s SGLIA interpretation.
• Queen v. United States, 99 F.4th 750 (5th Cir. 2024): De novo review of grants of summary judgment.
• Transamerica Life Ins. Co. v. Moore, 105 F.4th 823 (5th Cir. 2024): De novo review of questions of statutory interpretation.
• Guzman v. Allstate Assurance Co., 18 F.4th 157 (5th Cir. 2021): Credibility determinations are not appropriate at the summary judgment stage.

Legal Reasoning

The court began with FEGLIA’s text and structure, noting that § 8705(a) calls for a signed and witnessed writing “received before death in the employing office.” Neither the statute nor the implementing regulation demands an agency “indicia of receipt” such as a date-stamp, nor does either make validity contingent on the document’s presence in the personnel file.

To give content to “received,” the panel invoked Coomer, which construed SGLIA’s materially similar receipt requirement. Coomer held it is enough that the servicemember hands the form to the person designated to receive and maintain such records; subsequent administrative mishandling cannot defeat the insured’s validly expressed beneficiary designation. Because SGLIA was modeled on FEGLIA, and because the two statutes share nearly identical language for order-of-precedence and receipt, the Coomer definition was persuasive and applicable. The Fifth Circuit reiterated its general interpretive principle that similar language in similar statutes should be read similarly.

Applying that definition, the court concluded that the district court erred by layering extra-statutory requirements—either an “indicia of receipt” or personal-file presence—onto § 8705(a). FEGLIA’s text and regulations do not support those additions. Instead, so long as the insured delivers the properly executed designation to an appropriate person at the employing office before death, the statutory “received” requirement is met, regardless of later agency recordkeeping failures.

Turning to summary judgment, the widow produced: (1) a 2013 designation form properly signed by the insured and two witnesses, and (2) a sworn declaration from the insured’s supervisor who attested that he personally observed the insured copy the form and hand it to the on-duty HR personnel at the Dallas facility. The mother attacked the declaration’s credibility, but the panel emphasized that credibility disputes cannot be resolved at summary judgment. While the widow’s evidence did not entitle her to judgment as a matter of law, it created a genuine dispute of material fact sufficient to defeat the mother’s motion for summary judgment.

Finally, the court noted an unresolved factual question: whether handing the form to the HR official at the Dallas facility constitutes receipt “in the employing office” within the meaning of § 8705(a). Because the district court had not reached that issue, the Fifth Circuit left it for resolution on remand.

Impact and Implications

• Clarifies “Receipt” Under FEGLIA: In the Fifth Circuit, a FEGLI designation is “received” once the insured delivers the signed and witnessed form to appropriate employing-office personnel. There is no statutory or regulatory prerequisite of a date-stamp, acknowledgment, or placement in the personnel file.
• Insured’s Intent Protected from Recordkeeping Failures: The ruling prevents agency mishandling or loss of records from undoing an insured’s duly executed designation—aligning with Coomer’s core principle that administrative error cannot vitiate the insured’s expressed intent.
• Evidentiary Pathways at Summary Judgment: Witness testimony (e.g., from supervisors or HR personnel) can be sufficient to create a triable issue on “receipt.” Courts may see more factual trials in FEGLI disputes where paper trails are incomplete.
• Operational Incentives for Agencies: Although stamps and file-preservation are not required for validity, agencies now have stronger incentives to implement robust acknowledgment and archiving protocols to avoid litigation. Clear submission channels and uniform acknowledgment practices will reduce disputes.
• Guidance for Practitioners: Counsel should secure declarations from individuals who observed submission, collect contemporaneous emails or deployment paperwork that corroborate timing, and retain copies of signed-and-witnessed forms. Insurers may be less able to rely solely on the absence of a form in the personnel file to deny claims.
• Unresolved Boundary Questions: The decision does not define the “outer limits” of who qualifies as an “appropriate person” or the precise contours of “employing office.” Those questions will be fact-dependent and may turn on agency-specific submission protocols and organizational structures.
• Precedential Status: The opinion is unpublished (5th Cir. R. 47.5) and thus not binding precedent, but it is likely to be persuasive within the circuit and beyond, particularly because it harmonizes FEGLIA with longstanding SGLIA precedent.

Complex Concepts Simplified

• FEGLIA and Order of Precedence: FEGLIA provides life insurance to federal employees and prescribes who gets paid. If there is a valid designated beneficiary, that person gets paid first. If not, proceeds flow to the surviving spouse, then to other relatives per statutory priority.
• “Received … in the employing office”: This is FEGLIA’s timing and delivery requirement. The designation must be delivered before death to the employing office (typically the agency’s HR or benefits office). The Fifth Circuit holds that handing the form to appropriate HR personnel can satisfy “receipt.”
• Interpleader: When an insurer faces competing claims (here, the widow and the mother), it may file an interpleader to deposit the funds with the court and let the claimants litigate entitlement, shielding the insurer from multiple liability.
• Summary Judgment: A case can be decided without trial only if there is no genuine dispute of material fact. Credibility assessments are for the jury at trial, not for the judge at summary judgment.
• SGLIA vs. FEGLIA: SGLIA covers servicemembers; FEGLIA covers federal civilian employees. Because the statutes share similar structures and language (especially on beneficiary designations), courts sometimes interpret them consistently.

Conclusion

Metropolitan v. Vasquez supplies a clear, text-and-structure-focused interpretation of FEGLIA’s “received” requirement: delivery of a properly executed beneficiary designation to appropriate employing-office personnel is sufficient; neither an agency stamp nor the form’s presence in the personnel file is required. By aligning FEGLIA with the Fifth Circuit’s earlier SGLIA decision in Coomer, the panel ensures that an insured’s formally expressed intent is not nullified by later administrative mishaps. Practically, the decision sharpens the parties’ evidentiary burdens: witnesses with personal knowledge of delivery and contemporaneous documentation can be case-dispositive at trial.

Although unpublished, the reasoning is persuasive and will likely influence FEGLIA litigation strategy across the Fifth Circuit. On remand, the district court must determine whether the Dallas facility HR office qualifies as the “employing office” for receipt purposes—a reminder that the who-and-where of delivery can still be outcome determinative. For agencies and practitioners alike, the opinion underscores the importance of clear submission procedures, reliable acknowledgments, and meticulous recordkeeping—best practices that, while not mandated for validity, can avert costly disputes and ensure that benefits flow in accordance with the insured’s intent.

Key Takeaways

• “Received” under 5 U.S.C. § 8705(a) is satisfied by delivery to appropriate employing-office personnel; no stamp or file presence is required.
• Witness testimony can create a genuine dispute of material fact on receipt, defeating summary judgment.
• Administrative loss or misfiling does not vitiate a validly delivered and executed beneficiary designation.
• On remand, courts must assess whether the particular recipient and location qualify as the “employing office.”
• Agencies should adopt robust acknowledgment and retention practices; claimants should preserve copies and identify witnesses.