Irwin v. Irwin, 307 S.W.3d 383 (Tex. App.—San Antonio 2009, pet. denied).
The appellate court determined that an executor of an estate lacked
standing to litigate issues regarding the proper payment of life
insurance proceeds. Life insurance is a non-probate asset and the
insurance policy was not payable to the estate. Prob. Code § 450.
Moral: Disputes regarding the proper payment of life insurance proceeds
should be between the claimants to the proceeds, not the estate of the
insured unless the estate was the named beneficiary or would otherwise
be entitled to the proceeds.