Creditors Cannot Apply a Constructive Trust on Life Insurance Proceeds

A summary of Carts & Parts, Inc. v. Rosales, 225 P.3d 1 (Okla. Civ. App. 2009) is below:

A creditor of a deceased spouse sought to impose a constructive trust on the proceeds of insurance policies on the decedent’s life paid to the surviving spouse and in the meantime obtained a temporary injunction preventing the surviving spouse from disposing of the insurance proceeds. The Oklahoma intermediate appellate court overturned the injunction, holding that the statutory language exempting life insurance proceeds from claims against the insured or a beneficiary prevent the application of a constructive trust on the proceeds.