Legal Question in Insurance Law in Wisconsin

Re: Beneficiary Designation by Spouse

In Connecticut General Life Ins. Co. v. Merkel, 279 N.W.2d 715, 90 Wis.2d 126 (Wis.App. 1979), the Wisconsin Appellate Court stated: "We do not believe a marriage can be construed as a contract or promise by one spouse to name the other spouse as a beneficiary on a life insurance policy. To do so, we believe, would be against public policy and would create numerous practical problems."

My interpretation of this language is that this means a spouse may designate a beneficiary other than their spouse on a life insurance policy without that spouse's knowledge.