A consent judgment of divorce provided that all rights of either party to the proceeds of life insurance naming the other as beneficiary became payable to the estate of the policy owner or to a newly named beneficiary. The former wife died without removing husband as the named beneficiary of her life insurance policy. In the case of Rowley v Mac Innes, the Michigan Court of Appeals dermined that the husband waived his rights to the life insurance proceeds and was not entitled to retain them. Judge William Murphys concurred in the opinion. This case points out the importance of reviewing life insurance beneficiary designations on a periodic basis and keeping them up to date and reflective of the intent of the insured.