...requirements for application of the substantial-compliance doctrine. We affirm the judgment of the District Court.
The Honorable..., 704 N.E.2d at 561. Under both Missouri and New York law, a court may apply the equitable doctrine of substantial compliance to carry out the insured's intent where the insured has not strictly complied with the policy terms prescribing how to change a beneficiary. Anglen v. Heimburger, 803 S.W.2d 109, 112 (Mo.Ct.App. 1990); McCarthy, 681 N.Y.S.2d 790, 704 N.E.2d at 560. As a general rule, this doctrine makes...court stated that Missouri's substantial-compliance test contains two elements: (1) the insured's intent to change the beneficiary must be "established beyond question," and (2) the "insured has done everything possible under [the] circumstances."
Under New York law, the "paramount factor" in determining whether application of the substantial-compliance doctrine is...