J.G. WENTWORTH, S.S.C., L.P., A DELAWARE LIMITED PARTNERSHIP, APPELLANT,
v.
SAFECO LIFE INSURANCE COMPANY, APPELLEE
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J.G. Wentworth purchased an injured employee's right to receive annuity payments from a worker's compensation settlement. When the employee died, Safeco refused to honor the beneficiary change and payments, and the court affirmed that the entire assignment agreement violated Florida's statutory prohibition on assigning worker's compensation benefits.
The assignment agreement is invalid and unenforceable because Florida Statute section 440.22 prohibits all assignments of worker's compensation benefits except as specifically provided by statute. When documents are executed as part of the same transaction, they must be considered together, and the beneficiary change was an integral part of the assignment transaction.
[1] An agreement to assign, release, or commute workers' compensation benefits is invalid under Florida Statutes section 440.22.
[2] Documents executed as part of the same transaction must be considered together to determine their meaning and effect.
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Join FLexlaw to unlock all legal intelligence“No assignment, release, or commutation of compensation or benefits due or payable under this chapter except as provided by this chapter shall be valid, and such compensation and benefits shall be exempt from all claims of creditors, and from levy, execution and attachments or other remedy for recovery or collection of a debt, which exemption may not be waived.”
The statutory prohibition on assignment of worker's compensation benefits that renders the purchase agreement invalid.
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Join FLexlaw to unlock all legal intelligenceAn injured employee assigned her right to receive annuity payments from a worker's compensation settlement to J.G. Wentworth in exchange for a cash pa…
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WARNER, C.J.
Through a purchase agreement, an injured employee assigned her right to receive annuity payments from a worker’s compensation settlement to appellant for a cash payment. The employee agreed to change the beneficiary of the policy from her husband to her estate and to execute a will that would effectively transfer the estate’s interest in the continuing annuity payments to appellant. Pursuant to the agreement, the employee notified appellee, Safeco, of the change of beneficiary. When the employee died, Safeco refused to recognize the change of beneficiary and failed to make payments either to the employee’s estate or to appellant. Appellant filed suit, and Safeco defended, claiming that the entire agreement was invalid as a violation of section 440.22, Florida Statutes (1997), which provides:
No assignment, release, or commutation of compensation or benefits due or payable under this chapter except as provided by this chapter shall be valid, and such compensation and benefits shall be exempt from all claims of creditors, and from levy, execution and attachments or other remedy for recovery or collection of a debt, which exemption may not be waived.
The trial court agreed and granted summary judgment.
We affirm the trial court ruling. While appellant argues that Safeco should honor the change of beneficiary and let the estate recover, the employee’s agreement to change the beneficiary was simply part of the entire assignment of benefits transaction. Where documents are executed as part of the same transaction they should be considered together in determining their meaning and effect. See Holcomb v. Bardill, 214 So. 2d 522, 524 (Fla. 4th DCA 1968); Citicorp Real Estate, Inc. v. Ameri palms 6B GP, Inc., 633 So. 2d 47, 49 (Fla. 3d DCA 1994); Johnson v. Smith, 84 So. 2d 722, 725 (Fla.l956)(“contract between the parties consists not only of the promissory note but also of the several documents going to make up the composite agreement”). Section 440.22 makes any assignment of worker’s compensation benefits invalid. As such, this purchase agreement and its effectuating transfer instruments are unenforceable.
Affirmed.
DELL and TAYLOR, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
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Berkowitz v. Delaire Country Club, Inc., 126 So. 3d 1215 (Fla. 4th DCA 2012)…than one document, the documents should be considered together in interpreting the parties’ agreement.” Philips Lake Worth, L.P. v. BankAtlantic, 85 So. 3d 1221, 1225 (Fla. 4th DCA 2012) (citing J.G. Wentworth, S.S.C., L.P. v. Safeco Life Ins. Co., 755 So. 2d 138, 138 (Fla. 4th DCA 1999)). Further, Article XIX of the Articles of Incorporation states that in the event a conflict exists between the Articles of Incorporation and the By-laws, the Articles of Incorporation shall prevail. Article X of the Article…
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Philips Lake Worth, L.P. v. Bankatlantic, 85 So. 3d 1221 (Fla. 4th DCA 2012)…So. 2d 1019, 1020 (Fla. 4th DCA 2006) (citations omitted). Where an agreement comprises more than one document, the documents should be considered together in interpreting the parties’ agreement. J.G. Wentworth, S.S.C., L.P. v. Safeco Life Ins. Co., 755 So. 2d 138, 138 (Fla. 4th DCA 1999). If contract language is unambiguous, the language reflects the parties’ intent. Fecteau v. Se. Bank, N.A., 585 So. 2d 1005, 1007 (Fla. 4th DCA 1991). However, “[w]hen a contract is ambiguous and the parties suggest differen…
Authorities Cited
- Holcomb v. Bardill, 214 So. 2d 522 (Fla. 4th DCA 1968)
- Johnson v. Smith, 84 So. 2d 722 (Fla. 1956)
- Citicorp Real Est., Inc. v. Ameripalms 6B GP, Inc., 633 So. 2d 47 (Fla. 3d DCA 1994)