{ "id": 3559045, "name": "PRIMERICA LIFE INSURANCE COMPANY and Mary Jane Watson v. Ronda Gale WATSON", "name_abbreviation": "Primerica Life Insurance v. Watson", "decision_date": "2005-04-21", "docket_number": "04-1260", "first_page": "54", "last_page": "65", "citations": [ { "type": "official", "cite": "362 Ark. 54" }, { "type": "parallel", "cite": "207 S.W.3d 443" } ], "court": { "name_abbreviation": "Ark.", "id": 8808, "name": "Arkansas Supreme Court" }, "jurisdiction": { "id": 34, "name_long": "Arkansas", "name": "Ark." }, "cites_to": [ { "cite": "Ark. Code Ann. \u00a7 23-79-125", "category": "laws:leg_statute", "reporter": "Ark. Code Ann.", "year": 2004, "opinion_index": 0 }, { "cite": "532 U.S. 919", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 9308608, 9308646, 9308553, 9308458, 9308305, 9308340, 9308277, 9308246, 9308503, 9308376, 9308414 ], "year": 2001, "opinion_index": 0, "case_paths": [ "/us/532/0919-10", "/us/532/0919-11", "/us/532/0919-09", "/us/532/0919-07", "/us/532/0919-03", "/us/532/0919-04", "/us/532/0919-02", "/us/532/0919-01", "/us/532/0919-08", "/us/532/0919-05", "/us/532/0919-06" ] }, { "cite": "341 Ark. 282", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1257806 ], "weight": 2, "year": 2000, "opinion_index": 0, "case_paths": [ "/ark/341/0282-01" ] }, { "cite": "354 Ark. 682", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 36034 ], "weight": 2, "year": 2003, "opinion_index": 0, "case_paths": [ "/ark/354/0682-01" ] }, { "cite": "307 Ark. 379", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1902415 ], "weight": 4, "year": 1991, "pin_cites": [ { "page": "381-82" }, { "page": "455", "parenthetical": "emphasis added" } ], "opinion_index": 0, "case_paths": [ "/ark/307/0379-01" ] }, { "cite": "88 S.W.2d 76", "category": "reporters:state_regional", "reporter": "S.W.2d", "year": 1935, "opinion_index": 0 }, { "cite": "191 Ark. 825", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1418434 ], "year": 1935, "opinion_index": 0, "case_paths": [ "/ark/191/0825-01" ] }, { "cite": "282 Ark. 194", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1740732 ], "weight": 2, "year": 1984, "opinion_index": 0, "case_paths": [ "/ark/282/0194-01" ] }, { "cite": "47 S.W.2d 576", "category": "reporters:state_regional", "reporter": "S.W.2d", "year": 1932, "opinion_index": 0 }, { "cite": "185 Ark. 386", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1435129 ], "year": 1932, "opinion_index": 0, "case_paths": [ "/ark/185/0386-01" ] }, { "cite": "245 Ark. 563", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1606995 ], "weight": 4, "year": 1968, "opinion_index": 0, "case_paths": [ "/ark/245/0563-01" ] }, { "cite": "316 Ark. 345", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1907748 ], "weight": 4, "year": 1994, "opinion_index": 0, "case_paths": [ "/ark/316/0345-01" ] }, { "cite": "254 Ark. 983", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1624111 ], "weight": 2, "year": 1973, "pin_cites": [ { "page": "986" }, { "page": "658" } ], "opinion_index": 0, "case_paths": [ "/ark/254/0983-01" ] }, { "cite": "319 Ark. 566", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 1453645 ], "weight": 2, "year": 1995, "opinion_index": 0, "case_paths": [ "/ark/319/0566-01" ] }, { "cite": "357 Ark. 530", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 5403205 ], "weight": 2, "year": 2004, "opinion_index": 0, "case_paths": [ "/ark/357/0530-01" ] }, { "cite": "338 Ark. 467", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 243588 ], "weight": 2, "year": 1999, "opinion_index": 0, "case_paths": [ "/ark/338/0467-01" ] }, { "cite": "343 Ark. 8", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 226516 ], "weight": 2, "year": 2000, "opinion_index": 0, "case_paths": [ "/ark/343/0008-01" ] }, { "cite": "357 Ark. 482", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 5403443 ], "weight": 2, "year": 2004, "opinion_index": 0, "case_paths": [ "/ark/357/0482-01" ] }, { "cite": "Ark. Code Ann. \u00a7 23-79-208", "category": "laws:leg_statute", "reporter": "Ark. Code Ann.", "year": 2004, "opinion_index": 0 } ], "analysis": { "cardinality": 924, "char_count": 21649, "ocr_confidence": 0.746, "pagerank": { "raw": 1.7661576927106977e-07, "percentile": 0.7107207794740157 }, "sha256": "4e08636c00719b15047137e903a4063c414f7b9ad8d7d04f8706823916fbc8bc", "simhash": "1:3fcaa2a367c0ed93", "word_count": 3626 }, "last_updated": "2023-07-14T18:25:30.363503+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [ "Glaze, J., not participating in the opinion.", "Dickey, J., not participating." ], "parties": [ "PRIMERICA LIFE INSURANCE COMPANY and Mary Jane Watson v. Ronda Gale WATSON" ], "opinions": [ { "text": "Donald L. Corbin, Justice.\nThis case involves the determination of the rightful beneficiary to a life insurance policy issued to Gary Watson, deceased. Appellee Ronda Gale Watson is Gary\u2019s widow. Appellant Mary Jane Watson is his ex-wife. Following a jury trial, the White County Circuit Court entered an order declaring Ronda to be the beneficiary and awarding her the proceeds of Gary\u2019s fife insurance. Thereafter, the trial court ruled that Gary\u2019s insurer, Appellant Primerica Life Insurance Company, failed to pay Ronda\u2019s claim in a timely manner, and ordered it to pay a twelve-percent penalty plus Ronda\u2019s attorney\u2019s fees, pursuant to Ark. Code Ann. \u00a7 23-79-208 (Repl. 2004). Both Mary Jane and Primerica have appealed. Our jurisdiction of this case is pursuant to Ark. Sup. Ct. R. l-2(b)(6), as it requires us to interpret section 23-79-208. We affirm as to Mary Jane, but reverse as to Primerica.\nThe record reflects that in November 1987, Gary purchased a life insurance policy from Primerica in the amount of $100,000. Fie also purchased a spouse rider and a child rider. At the time, Gary was married to Mary Jane, and he named her the primary beneficiary, with his daughter being the contingent beneficiary. Gary and Mary Jane divorced in March 1993. Gary then married Ronda in July 1994. They were married for nine years, before Gary died from Lou Gehrig\u2019s disease on July 25, 2003.\nIn August 1996, while Gary was paying his life insurance premium, he commented to Ronda: \u201cWell, I guess I need to change the beneficiary on my policy, since I\u2019m going to keep you.\u201d Gary then asked Ronda to get him the telephone, and he called Primerica. Ronda heard Gary say that he was divorced and remarried, and that he needed to change the beneficiary on his policy. She said that he also stated that he needed to change the spouse rider and child rider.\nA few weeks later, Gary received a policy-change application from Primerica. On that form, he listed Ronda as his new spouse. According'to Ronda, who was present when he filled out the form, Gary noticed that there was no specific beneficiary form, so he wrote on the front page of the policy-change application \u201cchange name of spouse & change name of child rider.\u201d\nImmediately following Gary\u2019s death in July 2003, Ronda spoke to the funeral home about arrangements. Representatives of the funeral home asked if Gary had life insurance, and Ronda stated that he did. They then indicated that if Ronda would assign the proceeds to them, they would file a claim with the insurance company, deduct the funeral expenses, and then pay Ronda the difference. Primerica received the funeral home\u2019s claim on July 31.\nSometime in August, Ronda spoke with Michael Lynn, a claims representative for Primerica. Lynn told her that she was not the named beneficiary on the policy, but that Mary Jane was. Lynn then told her that he would look into the matter. After several conversations with Lynn, Ronda gave a copy of the policy to Tommy Bowers, a local insurance agent, and asked him to see if he could resolve the matter. Bowers subsequently told Ronda that the policy was \u201cfrozen,\u201d meaning that he could not get any information on it.\nRonda later had a conversation with Lynn, in which he told her that he could see Gary\u2019s intentions, but that it was not clear on paper. On September 11, Lynn called Ronda and asked her to get a copy of Gary\u2019s and Mary Jane\u2019s divorce decree. Ronda faxed it to him. The following day, Ronda received a call from a Primerica representative stating that everything was in order and that the company was about to cut her a check when Mary Jane called and claimed that she was the beneficiary. Primerica then advised Ronda to seek a settlement with Mary Jane, or it would file an action in interpleader. On September 15, Ronda told Primerica that a settlement could not be reached.\nOn September 25, before Primerica could file its action in interpleader, Ronda filed suit against Primerica and Mary Jane, asking the court to declare her the rightful beneficiary. The suit also alleged a claim of negligence against Primerica for failing to properly advise Gary about changing the beneficiary, for failing to provide the necessary forms, and for failing to follow Gary\u2019s instructions to name Ronda as his beneficiary. Ronda also sought the statutory penalty and attorney\u2019s fees from Primerica, pursuant to section 23-79-208.\nPrimerica filed an answer and counterclaim offering to interplead the funds of the policy and place them into the registry of the court. Primerica later sought and was granted summary judgment on Ronda\u2019s negligence claim. Thereafter, the case was tried to a jury, which found that Ronda was the beneficiary of the policy. Following a hearing held two weeks later, the trial court found that Ronda was entitled to the statutory penalty and attorney\u2019s fees. Judgment was entered on August 2, 2004, awarding Ronda the face amount of the policy plus interest, for a total of $106,887.33, plus a $12,000.00 penalty and $35,272.81 in attorney\u2019s fees.\nBoth Mary Jane and Primerica have appealed. For her sole point on appeal, Mary Jane argues that the trial court erred in allowing certain hearsay statements concerning Gary\u2019s intent to make Ronda the beneficiary of his life insurance and his belief that he had done so. Primerica argues that the trial court erred in assessing the statutory penalty and attorney\u2019s fees against it, pursuant to section 23-79-208. We address each appeal separately.\nStatements of Gary\u2019s Intention and Belief\nMary Jane argues that the trial court erred in allowing Ronda to testify about what she heard Gary tell a Primerica representative in the August 1996 telephone conversation. She also argues that it was error to allow Ronda to present testimony from five other witnesses about what Gary had told them about Ronda being the beneficiary of his life insurance. She argues that this evidence, especially that from the five other witnesses, was irrelevant and was unfairly prejudicial. She seeks a new trial that excludes this testimony.\nThe sole issue presented to the jury was whether Gary had changed his life insurance policy in a way that named Ronda as the beneficiary. The jury was instructed as follows:\nThe parties do not dispute that Gary Newman Watson and Primerica Life Insurance Company entered into an insurance contract.\nThe parties do not dispute that Primerica Life Insurance Company issued a contract of insurance which insured the life of Gary Watson for $100,000.00. The initial policy named Mary [Jane] Watson as beneficiary. Ronda Gale Watson contends Gary Watson changed the contract of insurance to name her as the beneficiary. Ronda Gale Watson has the burden of proving, pursuant to Arkansas law, that the insurance contract was changed to her name as the beneficiary.\nYou are instructed that the law of the State of Arkansas is that an insured must substantially comply with the provisions of a life insurance policy pertaining to a change of beneficiary, and that when an insured does everything within his power to make a change of beneficiary pursuant to the terms of the policy, a change of beneficiary is presumed.\nMary Jane argues that because the only issue for the jury to consider was whether Gary did everything in his power to change the beneficiary from her to Ronda, testimony as to his intention and belief was not relevant. We disagree.\nWe note at the outset that trial courts are accorded wide discretion in evidentiary rulings, and we will not reverse such rulings absent a manifest abuse of that discretion. Mays v. St. Pat Properties, LLC, 357 Ark. 482, 182 S.W.3d 84 (2004); Barker v. Clark, 343 Ark. 8, 33 S.W.3d 476 (2000); Jackson v. Buchman, 338 Ark. 467, 996 S.W.2d 30 (1999). \u201cHearsay\u201d is defined as \u201ca statement, other than one made by the declarant while testifying at the trial or hearing, offered in evidence to prove the truth of the matter asserted.\u201d Ark. R. Evid. 801(c). As a rule, hearsay is not admissible except as provided in our rules of evidence. See Ark. R. Evid. 802. Exceptions to this rule are found in Ark. R. Evid. 803 and 804. The exception found in Rule 803(3) is applicable in this case and provides:\nThen Existing Mental, Emotional, or Physical Condition. A statement of the declarant\u2019s then existing state of mind, emotion, sensation, or physical condition, such as intent, plan, motive, design, mental feeling, pain, and bodily health, but not including a statement of memory or belief to prove the fact remembered or believed unless it relates to the execution, revocation, identification, or terms of declarant\u2019s will.\nUnder Rule 803(3), a declarant\u2019s statement that he or she intends to do something in the future is admissible to prove the truth of the matter asserted. See Wyles v. State, 357 Ark. 530, 182 S.W.3d 142 (2004); Nicholson v. State, 319 Ark. 566, 892 S.W.2d 507 (1995). Gary\u2019s statement to Ronda, \u201cWell, I guess I need to change the beneficiary on my policy, since I\u2019m going to keep you,\u201d falls squarely within this exception, as it reflected Gary\u2019s intention to change the policy. Similarly, the statement that Gary made to his stepson, Chris Bargiel, that he was buying insurance and that Ronda would be the beneficiary, falls within this exception. The trial court did not err in allowing testimony about these statements.\nNor did the trial court err in allowing Ronda to testify about Gary\u2019s conversation to a Primerica representative, in which she heard Gary tell the representative that he was divorced and remarried, and that he needed to change the beneficiary on his policy, as well as the spouse rider and child rider. This statement manifested Gary\u2019s intent to change the beneficiary on his policy and was therefore admissible under the hearsay exception found in Rule 803(3). Moreover, this statement was highly relevant to the issue whether Gary had done everything in his power to change the beneficiary on his policy.\nFinally, the testimony given by Velton Fulton, Marvin Hughes, Thelma Hare, and Judy Monday, regarding statements that Gary made to them that Ronda would have the proceeds of his life insurance to pay off the debts of his business, was also admissible under Rule 803(3). These statements evidenced Gary\u2019s belief that Ronda was the beneficiary of his life insurance policy and his intention that she be entitled to the proceeds of that policy. Generally speaking, statements of a declarant\u2019s belief are not admissible under Rule 803(3), unless the statements relate to the execution, revocation, identification, or terms of the declarant\u2019s will. This court has recognized that provisions in life insurance contracts with reference to beneficiaries or changes in beneficiaries are in the nature of a last will and testament and, therefore, \u201care construed in accordance with the rules applicable to the construction of wills.\u201d See American Found Life Ins. Co. v. Wampler, 254 Ark. 983, 986, 497 S.W.2d 656, 658 (1973). As such, the testimony from the foregoing witnesses was properly admitted by the trial court under Rule 803(3). We thus affirm Mary Jane\u2019s appeal.\nStatutory Penalty and Attorney\u2019s Fees\nFor its appeal, Primerica argues that the trial court erred in assessing a twelve-percent penalty and attorney\u2019s fees against it under section 23-79-208. Alternatively, it argues that the trial court erred in the amount of attorney\u2019s fees it awarded.\nSection 23-79-208 provides in pertinent part:\n(a)(1) In all cases in which loss occurs and the cargo, property, marine, casualty, fidelity, surety, cyclone, tornado, life, accident and health, medical, hospital, or surgical benefit insurance company and fraternal benefit society or farmers\u2019 mutual aid association or company liable therefor shall fail to pay the losses within the time specified in the policy after demand is made, the person, firm, corporation, or association shall be liable to pay the holder of the policy or his or her assigns, in addition to the amount of the loss, twelve percent (12%) damages upon the amount of the loss, together with all reasonable attorney\u2019s fees for the prosecution and collection of the loss. [Emphasis added.]\nThis provision is penal in nature and is therefore strictly construed in favor of the party sought to be penalized. State Farm Mut. Auto. Ins. Co. v. Thomas, 316 Ark. 345, 871 S.W.2d 571 (1994); Clark Center, Inc. v. National Life & Accident Ins. Co., 245 Ark. 563, 433 S.W.2d 151 (1968). It should not be held to apply except in cases that come clearly within the statute. National Fire Ins. Co. v. Kight, 185 Ark. 386, 47 S.W.2d 576 (1932).\nThe penal nature of the statute is directed against the unwarranted delaying tactics of insurers. Thomas, 316 Ark. 345, 871 S.W.2d 571; Simmons First Nat\u2019l Bank v. Liberty Mut. Ins. Co., 282 Ark. 194, 667 S.W.2d 648 (1984). However, not every delay is an unwarranted delaying tactic. For example, this court has held that an insurer is allowed a reasonable time to investigate a claim where the insurer in good faith believes that an investigation is necessary before making payment. Clark Center, Inc., 245 Ark. 563, 433 S.W.2d 151. This court has also held that where there is a proper question as to the rightful beneficiary, which the parties cannot determine or settle among themselves, the insurer is not responsible for the statutory penalty and attorney\u2019s fees for the delay resulting from filing a complaint in interpleader. See Dennis v. Equitable Life Assur. Soc., 191 Ark. 825, 88 S.W.2d 76 (1935).\nPrimerica urges that it did not engage in unwarranted delaying tactics in this case. It contends that it stood ready, willing, and able to pay the proceeds of the policy, but that when it was faced with claims from both Ronda and Mary Jane, it advised the two claimants that if they could not work out a settlement, it would file an action in interpleader and let the court determine who was the rightful beneficiary. It contends that both claims were legitimate, as Mary Jane was the beneficiary named in the policy, while Ronda was the deceased\u2019s widow. It contends that if it had paid one claimant to the exclusion of the other, it would have placed itself in the dangerous position of exposing itself to liability to both claimants. It contends further that by interpleading the parties and requesting that the funds be deposited into the registry of the court, it denied no one recovery. Rather, it merely took the position that it wanted to pay, but could not determine the rightful payee. We agree.\nOur holding in USAble Life v. Fow, 307 Ark. 379, 820 S.W.2d 453 (1991), is instructive. There, the insurer issued a group life insurance policy to the deceased, in which his wife was the named beneficiary. Prior to his death, the deceased executed a change of beneficiary form naming his daughters as his beneficiaries. Upon his death, the daughters submitted a written claim for the proceeds of the policy. The deceased\u2019s wife also made a claim for the proceeds. In a telephone call to the insurer, the wife threatened to institute a lawsuit if she did not receive the proceeds. The insurer requested the wife to provide documentation in support of her claim, but she failed to do so. Thereafter, the insurer filed a complaint in interpleader asking the trial court to determine the beneficiaries as among the two daughters and the wife. The daughters objected and counterclaimed against the insurer for the statutory penalty and attorney\u2019s fees. The trial court ruled in favor of the daughters. On appeal, the insurer argued that the fact that it never denied liability and promptly filed a complaint in inter-pleader absolved it of any liability for the statutory penalty or attorney\u2019s fees. This court disagreed, holding:\nIn this case, USAble Life\u2019s policy provided that it had 90 days within which to pay claims after it had been notified of a loss. Although USAble Life has never denied liability for this claim, it is undisputed that it had in its files the change of beneficiary form naming [the daughters] as current benrficiaries of [the deceased\u2019s] policy. Further, it is clear that USAble Life did not make an investigation as to the proper party for payment or make payment of the policy proceeds to [the daughters] as named beneficiaries, but chose instead to initiate an action for interpleader apparently based on [the wife\u2019s] verbal claims and the threat of a lawsuit. By doing so, USAble Life avoided what it considered to be a potential lawsuit by filing an action in interpleader, while at the same time placing the burden on [the daughters] to bear legal expenses in perfecting their claim to the monies that were rightfully theirs as current beneficiaries under the policy.\nId. at 381-82, 820 S.W.2d at 455 (emphasis added).\nIn the present case, unlike in Fow, the insurer, Primerica, did not deny payment to the named beneficiary based only on a verbal threat of lawsuit from another party. Although Ronda was later determined to be the rightful beneficiary, at the time of her claim, she was not the named beneficiary, Mary Jane was. Primerica viewed the policy-change application executed by Gary in August 1996 as only changing the name of the spouse and the spouse rider from Mary Jane to Ronda, but not changing the designation of Mary Jane as beneficiary. Once Mary Jane made a claim on the proceeds of the policy, Primerica decided to inter-plead the funds into the registry of the court and allow the court to determine the rightful beneficiary, unless Ronda and Mary Jane could work out a settlement. Upon being informed that the parties could not reach a settlement, Primerica obtained local counsel to file the complaint in interpleader. Before it could do so, however, Ronda filed suit against Primerica and Mary Jane. We do not view the actions taken by the insurer in this case as being tantamount to the kind of unwarranted delaying tactics envisioned by section 23-79-208.\nNor do we agree with Ronda\u2019s suggestion that section 23-79-208 is triggered anytime a claimant has to file suit to recover the insurance proceeds, regardless of the factual circumstances. The statute contains no such language, and we will not read into it that which is not there. As stated above, section 23-79-208 is penal in nature and is therefore strictly construed by this court in favor of the party sought to be penalized. Strict construction means that nothing is taken as intended which is not clearly expressed. See Hunt v. State, 354 Ark. 682, 128 S.W.3d 820 (2003); Wilson v. Neal, 341 Ark. 282, 16 S.W.3d 228 (2000), cert. denied, 532 U.S. 919 (2001).\nFinally, Ronda asserts that Primerica\u2019s claim that it could have been exposed to having to pay the claim twice had it not chosen to pursue interpleader is not valid. She asserts that Primerica could have paid the proceeds to her and then invoked the protection from double exposure provided in Ark. Code Ann. \u00a7 23-79-125 (Repl. 2004). That section provides:\n(a) Whenever the proceeds of or payments under a life or accident and health insurance policy or annuity contract become payable in accordance with the terms of the policy or contract, or the exercise of any right or privilege thereunder, and the insurer makes payment of the amount in accordance with the terms of the policy or contract or in accordance with any written assignment thereof, the person then designated in the policy or contract or by the assignment as being entitled to the benefits shall be entitled to receive the proceeds or payments and to give full acquittance therefor.\n(b) The payments shall fully discharge the insurer from all claims under the policy or contract unless, before payment is made, the insurer has received at its home office written notice by or on behalf of some other person that the other person claims to be entitled to the payment or some interest in the policy or contract. [Emphasis added.]\nWe agree with Primerica that the protection offered by subsection (b) is only available when the insurer pays the proceeds over to \u201cthe person then designated in the policy ... as being entitled to the benefits,\u201d as provided in subsection (a). In this case, it was Mary Jane, not Ronda, who was the person then designated in the policy as being entitled to receive the proceeds. Thus, contrary to Ronda\u2019s urging, Primerica\u2019s payment to Ronda would not have discharged it from having to pay a claim from Mary Jane.\nWe thus reverse the trial court\u2019s award of a twelve-percent penalty and attorney\u2019s fees to Ronda, as we hold that the provisions of section 23-79-208 were not triggered by Primerica\u2019s actions. Accordingly, it is not necessary to address Primerica\u2019s alternative argument that the amount of attorney\u2019s fees was excessive.\nAffirmed in part; reversed in part.\nGlaze, J., not participating in the opinion.\nDickey, J., not participating.\nIn her brief on appeal, Mary Jane seems to concede that the hearsay testimony from Ronda was not unfairly prejudicial, in that it was counterbalanced by her own testimony about statements that Gary had made to her about her being the beneficiary. Mary Jane\u2019s brief reflects her conclusion that the jury likely discounted both women\u2019s testimony and looked to other evidence.", "type": "majority", "author": "Donald L. Corbin, Justice." } ], "attorneys": [ "Watts, Donovan & Tilley, P.A., by: Richard N. Watts and Staci Dumas Carson, for appellant, Primerica Life Insurance Company.", "Killough Law Firm, by: Larry Killough, Jr., for appellant, Mary Jane Watson.", "Lightle, Raney, Bell & Simpson, LLP, by: A. Watson Bell, for appellee." ], "corrections": "", "head_matter": "PRIMERICA LIFE INSURANCE COMPANY and Mary Jane Watson v. Ronda Gale WATSON\n04-1260\n207 S.W.3d 443\nSupreme Court of Arkansas\nOpinion delivered April 21, 2005\nWatts, Donovan & Tilley, P.A., by: Richard N. Watts and Staci Dumas Carson, for appellant, Primerica Life Insurance Company.\nKillough Law Firm, by: Larry Killough, Jr., for appellant, Mary Jane Watson.\nLightle, Raney, Bell & Simpson, LLP, by: A. Watson Bell, for appellee." }, "file_name": "0054-01", "first_page_order": 76, "last_page_order": 87 }