In Kowalski v. Jackson National Life Ins. Co., et. al., 2013 WL 5954380 (S.D. Fla. 2013), Edward Kowalski owned a policy on his mother, Florence, and he was the beneficiary. He died and his wife, Lisa, became the owner but never changed the beneficiary. For three years Lisa paid the premiums until Florence died. The court noted that Lisa thought she was the beneficiary, could have made herself beneficiary because she was the policy owner and thus awarded the proceeds to Lisa, rather than Edward’s estate, on an unjust enrichment theory.