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Beneficiary Account with No Designation Sparks Litigation

Bequests in the News
June 3, 2026

This Doesn’t Happen Everyday!

Movie mogul Samuel Goldwyn was fond of saying that “an oral contract isn’t worth the paper it’s written on,” and this is usually quite true in the world of bequests.

The case of Glass v. Delong, 2025 WL 2589289 (Pa. Super.) is a rare exception to that principle and thus merits a bit of attention. The litigation lasted four years. Our summary boils it down to its essentials.

Jeffrey George died unexpectedly in 2021. He was not married but was in a longtime relationship with Elizabeth Glass. The two enjoyed a “monogamous common domestic life together, commingling assets and other financial obligations.” Mr. George had not prepared a will. Under Pennsylvania’s intestacy laws, Michele Delong (his sister) was the sole beneficiary of his estate.

Apart from his assets co-owned with Ms. Glass, the bulk of the decedent’s wealth consisted of five retirement accounts worth well over $1 million held by three different custodians. It does not appear that there were valid designations on any, or at least most, of those accounts at the time of Mr. George’s death. Under standard probate law, including that of Pennsylvania, such undesignated accounts become the property of the estate and, in this case, would pass to Ms. Delong (the sister).

Under standard probate law, including that of Pennsylvania, such undesignated accounts become the property of the estate…

Ms. Glass launched litigation to claim the retirement accounts, asserting that she and the decedent had a longstanding oral agreement to name each other on such accounts. Discovery revealed that Mr. George had acknowledged the arrangement to various financial counselors but failed to formalize it on the official designation forms that custodians require.

Ms. Glass had been more diligent and correctly named Mr. George on similar accounts that she owned individually. The probate court found that there was adequate evidence of the oral contract between the deceased and his partner, and the appeals court affirmed that ruling. The George accounts therefore were given to Ms. Glass.

Ms. Glass launched litigation to claim the retirement accounts, asserting that she and the decedent had a longstanding oral agreement to name each other on such accounts. Discovery revealed that Mr. George had acknowledged the arrangement to various financial counselors but failed to formalize it on the official designation forms that custodians require. Ms. Glass had been more diligent and correctly named Mr. George on similar accounts that she owned individually. The probate court found that there was adequate evidence of the oral contract between the deceased and his partner, and the appeals court affirmed that ruling. The George accounts therefore were given to Ms. Glass.