The U.S. Court of Appeals for the Seventh Circuit has ruled in a complex retirement plan beneficiary dispute that highlights the importance of proper procedures when changing beneficiary designations after divorce. The case, *Packaging Corporation of America Thrift Plan for Hourly Employees v. Dena Langdon*, involves multiple parties competing for retirement benefits after a plan participant's death.

Carl Kleinfeldt participated in a retirement plan administered by his employer, Packaging Corporation of America (PCA). He had designated his wife, Dena Langdon, as the primary beneficiary of the account. Following their divorce in September 2022, Kleinfeldt attempted to remove Langdon as the primary beneficiary by sending a fax to PCA's benefits center.

However, when Kleinfeldt died in January 2023, just four months after the divorce, Langdon remained listed as the primary beneficiary of the retirement account. This created a dispute between Kleinfeldt's estate and his ex-wife over the funds in the account, leading to litigation that would ultimately involve multiple parties and complex legal questions about beneficiary designation procedures.

Faced with competing claims to the retirement benefits, PCA initiated an interpleader action in federal district court against both the estate and Langdon. An interpleader action allows a party holding disputed funds to deposit them with the court and let the competing claimants resolve their dispute, while the original holder is dismissed from the case. PCA was subsequently dismissed from the action after filing the interpleader.

The case became more complicated when the district court determined that Kleinfeldt's sister, Terry Scholz, also had a potential interest in the funds as a surviving contingent beneficiary. The court joined Scholz's estate as a necessary party to the litigation after she died following Kleinfeldt's death, ensuring all potential beneficiaries were represented in the proceedings.

Both the estate and Langdon filed cross-motions for summary judgment, seeking to resolve the dispute without a trial. However, before ruling on those motions, the district court made a determination that would prove controversial on appeal. The court invoked what is known as the "substantial compliance doctrine" to find that Kleinfeldt had successfully removed Langdon as the beneficiary of the retirement account, despite the fact that she remained listed as the primary beneficiary at the time of his death.

The substantial compliance doctrine is a legal principle that allows courts to find that procedural requirements have been met even when there are technical deficiencies, as long as the intent of the requirements has been substantially satisfied. In this case, the district court apparently determined that Kleinfeldt's fax to PCA's benefits center, requesting Langdon's removal as beneficiary, was sufficient to accomplish the change even though the plan records were not updated before his death.

Based on this finding, the district court granted summary judgment sua sponte in favor of Scholz's estate. A sua sponte ruling means the court acted on its own initiative rather than in response to a specific motion from one of the parties. This suggests the court determined that Scholz, as the contingent beneficiary, was entitled to the retirement benefits once Langdon was deemed to have been properly removed as the primary beneficiary.

The case raises important questions about the requirements for changing beneficiary designations under the Employee Retirement Income Security Act (ERISA), which governs most employer-sponsored retirement plans. ERISA plans typically have specific procedures that must be followed to change beneficiaries, and courts must balance the need for certainty and proper documentation against the desire to honor a deceased participant's intent.

The dispute also illustrates the complexities that can arise when marriages end and financial arrangements must be untangled. While divorce decrees often address the division of retirement benefits, the actual beneficiary designations on the plans themselves must be changed separately through the plan administrator's procedures.

The Seventh Circuit's decision in this case, issued February 2, 2026, after oral arguments in December 2025, will likely provide important guidance for similar disputes involving retirement plan beneficiaries. The case demonstrates the critical importance of following proper procedures when attempting to change beneficiary designations, particularly in situations involving divorce or other family law matters.

For plan participants, the case serves as a reminder to ensure that beneficiary changes are properly completed and confirmed with the plan administrator. For legal practitioners, it highlights the need to carefully review beneficiary designation procedures and ensure compliance with both plan requirements and ERISA standards when advising clients on retirement planning matters.