CourtListener opinion 10804904

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02/24/2025
 IN THE COURT OF APPEALS OF TENNESSEE
 AT NASHVILLE
 August 7, 2024 Session

THOMAS FURTSCH, PERSONAL REPRESENTATIVE OF THE ESTATE
 OF MICHAEL EDWARD BIRDWELL v. TAMMY ANN O'DELL

 Appeal from the Chancery Court for Putnam County
 No. 2023-6 Ronald Thurman, Chancellor
 ___________________________________

 No. M2024-00025-COA-R3-CV
 ___________________________________

This appeal involves a claim for breach of contract filed by the personal representative of
a deceased husband's estate against his former wife, asserting that the former wife breached
the parties' marital dissolution agreement by accepting the proceeds of the former
husband's retirement account upon his death. The parties' marital dissolution agreement
had provided that the retirement account would be "the sole and absolute property of the
Husband" and that any "marital interest" the wife had was divested from her and vested in
the husband. However, the wife remained the designated beneficiary of the account when
the husband died six years later. Cross-motions for summary judgment were filed by the
estate and by the wife. The trial court granted summary judgment to the estate, concluding
that the wife breached the marital dissolution agreement and that the estate was entitled to
the entire sum in the account. The wife appeals. For the following reasons, we reverse the
decision of the chancery court and remand for further proceedings.

 Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Chancery Court Reversed
 and Remanded

CARMA DENNIS MCGEE, J., delivered the opinion of the court, in which W. NEAL
MCBRAYER and JEFFREY USMAN, JJ., joined.

Sharon Reynolds Clark and Patrick C. Cooley, Kingston, Tennessee, for the appellant,
Tammy Ann O'Dell.

Michael D. Galligan, McMinnville, Tennessee, for the appellee, Thomas Furtsch, Personal
Representative of the Estate of Michael Edward Birdwell.

 OPINION
 I. FACTS & PROCEDURAL HISTORY

 Michael Edward Birdwell and Tammy Ann O'Dell were divorced by decree in
2015. At that time, Mr. Birdwell had a retirement account resulting from his employment
with Tennessee Tech, and Ms. O'Dell was designated as the beneficiary. The final decree
incorporated and adopted a marital dissolution agreement executed by the parties, which
contained the following provisions that are pertinent to this appeal:

 This agreement made and entered into on this the 23 day of October, 2015,
 by and between MICHAEL E. BIRDWELL, hereinafter referred to as
 Husband and TAMMY A. O'DELL hereinafter referred to as Wife.
 ...
 WHEREAS, the parties hereto desire to make a complete and final settlement
 of all property now owned by the parties hereto and to settle all claims as to
 any property which may here and after be acquired by them; and
 NOW, THEREFORE, for and in consideration of the premises hereinabove
 contained, the parties hereto agree as follows:
 ...
 SIXTH: The parties agree that they will receive their own separate savings,
 checking, retirement or any other accounts that are currently maintained in
 their name. Specifically the Husband has a retirement account with TIAA-
 CREFF which shall be the sole and absolute property of the Husband. Any
 marital interest either party has in and to said accounts is hereby divested out
 of them and vested in the party receiving the account as their sole separate
 property. The joint savings account at Progressive Savings Bank ending in
 2996 shall be the sole and absolute property of Tammy A. O'Dell.
 ...
 ELEVENTH: It is understood and agreed between the parties, as part of the
 consideration for the execution of this Agreement, that each party shall
 willingly execute and deliver any and all instruments necessary or required
 in order to implement the terms of this Agreement.
 ...
 THIRTEENTH: It is understood and agreed between the parties that this
 Agreement is intended to be a final settlement of all property rights of the
 respective parties hereto and is a discharge from all of the claims arising out
 of their marital relationship, and that each hereby waives and relinquishes to
 the other all rights or claims which each may have or hereafter acquire under
 the law of any jurisdiction of the other's property, including without
 limitation, dower, curtsey, statutory allowance, homestead rights, right to
 take against the will of the other, inheritance, descent or distribution or right
 to as Administrator or Executor of the other's estate, and this Agreement
 applies to all property now owned by the Wife and Husband, or any property
 -2-
 that either of them may acquire in the future.
 FOURTEENTH: This Agreement shall be binding upon and inure to the
 benefit of the parties hereto, their personal representatives, heirs and assigns.

Mr. Birdwell was represented by counsel during the divorce proceedings, while Ms. O'Dell
was not.

 Six years later, in February 2022, Mr. Birdwell executed a power of attorney naming
Dr. Jeff Roberts and another individual as his co-attorneys in fact. At that time, Mr.
Birdwell was physically ill but mentally competent. According to Dr. Roberts, Mr.
Birdwell asked him to change the beneficiary designation on his retirement account from
his ex-wife to his estate. In his capacity as attorney in fact, Dr. Roberts submitted
documents attempting to change the beneficiary designation on Mr. Birdwell's retirement
account from Ms. O'Dell to Mr. Birdwell's estate. Despite multiple attempts, however,
the companies maintaining the retirement account refused to change the beneficiary
designation.1 Mr. Birdwell died on March 20, 2022. He left a will dated February 2022.
Ms. O'Dell was not a beneficiary of Mr. Birdwell's estate under any provision of his will.
However, Ms. O'Dell remained the named beneficiary on Mr. Birdwell's retirement
account as of the date of his death. TIAA sent correspondence to Ms. Odell, requesting
documents in order to begin the process of transferring the benefits of the retirement
account to her. After Ms. O'Dell completed the necessary documents to claim the benefits,
including a beneficiary acceptance form, she received the proceeds of the retirement
account, which totaled $269,851.64. The residual beneficiaries under Mr. Birdwell's will
were the Dr. Michael Birdwell Travel Fund of the History Department at Tennessee
Technological University and WCTE, Inc.

 The personal representative of Mr. Birdwell's Estate filed this lawsuit against Ms.
O'Dell in January 2023. The complaint asserted three causes of action – breach of contract,
unjust enrichment, and conversion. For the breach of contract claim, the complaint alleged
that Ms. O'Dell's "acceptance of the proceeds" of the retirement account constituted a
"failure to perform her obligations" under the marital dissolution agreement because she
was completely divested of all interest in the account and was required to take action
necessary to effectuate that divestment. The Estate sought to recover the entire amount of
the retirement account proceeds in addition to interest and attorney fees. Ms. O'Dell filed
an answer, admitting that she received the proceeds from the retirement account as the pay
on death beneficiary but denying that the Estate was entitled to relief.

 The Estate filed a motion for summary judgment only on the claim for breach of
contract. The Estate asserted that there were no genuine issues of material fact and the

 1
 In the event that the account owner had a duly executed power of attorney, in order for the
attorney in fact to change the beneficiary, TIAA required the power of attorney to include language
permitting the attorney in fact to make changes to beneficiary designations on accounts.
 -3-
 only question before the court was whether, as a matter of law, Ms. O'Dell breached a
material provision of the marital dissolution agreement.2 The Estate pointed out that the
marital dissolution agreement said the account would be Mr. Birdwell's "sole and absolute
property" and that any marital interest would be divested from Ms. O'Dell and vested in
him. It also noted the language stating that each party waived and relinquished to the other
"all rights or claims which each may have or hereafter acquire under the law of any
jurisdiction of the other's property." The Estate also noted that Ms. O'Dell agreed to
execute any instruments to implement the marital dissolution agreement, and the parties
intended the agreement to constitute a final settlement of all property rights. Thus, the
Estate argued that Ms. O'Dell was divested of "any interest whatsoever" in the retirement
account, she had a continuing obligation to execute documents to effectuate this, and
instead she did "the exact opposite" by executing documents to accept the funds after his
death. The Estate contended that there was no need for Mr. Birdwell to change the
beneficiary designation prior to his death because the marital dissolution agreement itself
divested Ms. O'Dell of her interest and required her to execute any necessary documents
to that effect. In support of its position, the Estate relied on this Court's decisions in
Lunsford v. Lunsford, No. M2004-00662-COA-R3-CV, 2005 WL 2572389 (Tenn. Ct.
App. Oct. 12, 2005), and Manning v. Manning, No. E2015-02082-COA-R3-CV, 2016 WL
3640317 (Tenn. Ct. App. June 30, 2016). The Estate also submitted numerous documents
in support of its motion along with a statement of undisputed material facts.

 Ms. O'Dell filed a response to the motion for summary judgment. She contended
that the marital dissolution agreement only divested her of the marital interest she held in
the retirement account, but the beneficiary designation was not a marital interest, so the
agreement did not impact her capacity to be designated as a beneficiary. Ms. O'Dell
claimed that a change to the beneficiary designation was never an express or intended term
of the agreement. She contended that Mr. Birdwell did become the "sole and absolute"
owner of the retirement account after the divorce and that he was vested with all property
rights related to the account, including the right to designate any beneficiary he chose
without her participation or approval. She also claimed that her obligation to execute
documents only extended to those necessary to implement the agreement's terms, and it
did not extend to any release of rights as a named beneficiary of the retirement account.
Ms. O'Dell submitted her own affidavit in which she stated that she was never asked by
Mr. Birdwell to sign any document to change the beneficiary designation. As such, Ms.
O'Dell argued that she "fully performed the terms of the MDA" and did not breach it. Ms.
O'Dell claimed that she had "lawfully received" the funds as the properly named
beneficiary on the account. In support of her position, Ms. O'Dell relied on Bowers v.
Bowers, 637 S.W.2d 456 (Tenn. 1982), and argued that the Lunsford and Manning cases
cited by the Estate were distinguishable. Ms. O'Dell also filed her own motion for
summary judgment, restating these arguments regarding the breach of contract claim, but

 2
 The Estate took the position that the claim for breach of contract should be decided before the
claims for unjust enrichment and conversion.
 -4-
 her motion also addressed the claims for conversion and unjust enrichment. Ms. O'Dell
argued that, under Tennessee law, a marital dissolution agreement has been held to
effectuate a change in beneficiary only in rare circumstances, and the facts of this case did
not fit into one of those "rare exceptions" recognized in Lunsford and Manning. Instead,
she argued that the result was controlled by the decision of the Tennessee Supreme Court
in Bowers.

 The Estate filed a response to Ms. O'Dell's motion for summary judgment,
reiterating the arguments from its own motion. The Estate maintained that the parties'
intention in the marital dissolution agreement, "notwithstanding legal jargon," was for Ms.
O'Dell to receive no benefit from the retirement account. The Estate also clarified that it
was not taking the position that Ms. O'Dell needed to execute any documents to effectuate
her divestiture; rather, the Estate only demanded that Ms. O'Dell not execute documents
enabling her to receive funds that did not belong to her. The Estate argued that Ms. O'Dell
submitted the necessary paperwork to receive the funds when "[t]he MDA prohibited her
from doing so." The Estate conceded that in most life insurance and annuity cases, a
marital dissolution agreement does not change beneficiary designations, but it argued that
Bowers was distinguishable because here the parties' marital dissolution agreement
specifically referred to Mr. Birdwell's retirement account, which, the Estate argued, was a
"critical" difference. The Estate insisted that Lunsford and Manning controlled the result
here.

 After a hearing, the trial court entered an order resolving the competing motions for
summary judgment. Finding no genuine issue of material fact, the trial court granted
summary judgment to the Estate and denied the motion filed by Ms. O'Dell. The trial
court's order stated that the court had considered all of the "filings and arguments" before
the court, but the order did not contain any discussion of the cases relied on by the parties,
such as Bowers, Lunsford, or Manning, nor did it cite any other legal authority in support
of its decision. Instead, the trial court stated that "the Court must look to the four corners
of the agreement and interpret it in a fair and just way, not reading anything into it but
looking at the plain meaning of the wording and try to glean what the interest of the parties
were at the time this was entered in 2015." The trial court deemed the language
unambiguous. It then made the following findings:

 25. Paragraph 6 of the MDA, which was adopted and approved by this
 Court in the final order, divests the marital interest that Ms. O'Dell
 had in Mr. Birdwell's TIAA Annuity and vested the same in him.
 26. In accordance with Paragraph 11, each party agreed to willingly
 execute and deliver any and all instruments necessary or required in
 order to implement the terms of their agreement.
 27. As a result of Paragraph six (6) of the parties MDA, Mr. Birdwell
 acquired Ms. O'Dell's marital interest back from her in his retirement
 contract.
 -5-
 28. Mr. Birdwell was then the sole owner of the retirement contract.
 29. Mr. Birdwell never took any steps to remove Ms. O'Dell from his
 TIAA Annuity after the parties were divorced.
 30. Ms. O'Dell did not waive her right to be a beneficiary of this account,
 however, Paragraph 13 basically says that the MDA was intended to
 apply to all marital rights that the parties had at the time of the divorce
 or any property that either of them may acquire in the future and it is
 that broad language of Paragraph 13 that invokes Paragraph 11 of the
 MDA which means that Ms. O'Dell agreed that if she acquired any
 rights in the future in the Retirement Account she would sign any
 documents necessary to divest herself from them.
 31. Without this language in Paragraph 13 of the MDA, Ms. O'Dell would
 be entitled to the assets of the TIAA Retirement Account.
 32. Paragraph 14 of the MDA makes the MDA binding on the parties and
 their personal representatives, heirs and assigns which means that the
 MDA entered into between Mr. Birdwell and Ms. O'Dell now inures
 to the Estate of Mr. Birdwell.
 33. Based upon the foregoing Findings, which are incorporated into this
 Court's Order by reference as though more fully set out, the Court
 grants the Motion for Summary Judgment of the Petitioner, the Estate
 of Birdwell, and denies the Respondent's Motion for Summary
 Judgment.

Ms. O'Dell filed a notice of appeal to this Court. Thereafter, an agreed order was entered,
amending the original summary judgment order to further provide that the Estate was
entitled to the relief sought based on the court's finding that Ms. O'Dell breached the
marital dissolution agreement. The agreed order further provided that "[a]ll other causes
of action of the Plaintiff are dismissed[.]"

 II. ISSUES PRESENTED

 Ms. O'Dell presents the following issues for review on appeal:

1. Whether the Chancery Court erred in finding the terms of the Marital Dissolution
 Agreement ("MDA") rather than the TIAA-CREF Retirement Accounts ("the
 Retirement Accounts") contracts controlled the distribution of the Retirement
 Accounts.
2. Whether the Chancery Court erred in finding that the terms of the MDA extended
 beyond a division of marital interests in property to include all interests in current
 and future property rights of the parties despite express terms limiting the scope of
 the contract to marital property.
3. Whether the Chancery Court erred in finding that the MDA required the parties to
 divest themselves of nonmarital property interests, specifically being a designated
 -6-
 beneficiary.
4. Whether the Chancery Court's interpretation of the MDA created an ambiguity in
 terms which it should have construed against Birdwell as the represented and
 drafting party of the MDA.

For the following reasons, we reverse the decision of the chancery court and remand for
further proceedings.

 III. STANDARD OF REVIEW

 Summary judgment is appropriate "if the pleadings, depositions, answers to
interrogatories, and admissions on file, together with the affidavits, if any, show that there
is no genuine issue as to any material fact and that the moving party is entitled to a judgment
as a matter of law." Tenn. R. Civ. P. 56.04. We review a trial court's decision on a motion
for summary judgment de novo with no presumption of correctness. Lemon v. Williamson
Cty. Sch., 618 S.W.3d 1, 12 (Tenn. 2021) (citing Tatham v. Bridgestone Ams. Holding,
Inc., 473 S.W.3d 734, 748 (Tenn. 2015)).

 IV. DISCUSSION

 On appeal, Ms. O'Dell maintains that the result in this case is controlled by the
Tennessee Supreme Court's decision in Bowers, and the cases that have "consistently"
followed its reasoning since it was decided. In response, the Estate argues that this Court's
decisions in Lunsford and Manning "created an exception to the holding in Bowers," and
this case "fits the exception." Consequently, we must examine the Bowers decision and
the many cases that have applied it over the years, as well as the few cases that have
distinguished it.

 We begin with Bowers, which was decided by the Tennessee Supreme Court in
1982. Bowers, 637 S.W.2d at 456. In that case, the husband had a life insurance policy
through his employer,3 and his wife was named as sole beneficiary of the policy during
their marriage. Id. at 457. They subsequently divorced and executed a property settlement
 3
 "[W]hen the right to change the beneficiary [of a life insurance policy] has been reserved to the
insured/owner and is not otherwise overridden, ‘the beneficiary named in the policy has a mere expectancy
and has no vested right or interest in the policy.'" Holmes v. Karkau, No. M2021-00696-COA-R3-CV,
2022 WL 1232910, at *5 (Tenn. Ct. App. Apr. 27, 2022) (quoting First Nat'l. Bank of Shelbyville v. Mut.
Benefit Life Ins. Co., 732 S.W.2d 278, 279 (Tenn. Ct. App. 1987)). This mere expectancy "‘does not rise
to the dignity of a property right.'" Id. at *6 (quoting Fidelity Mut. Life Ass'n v. Winn, 33 S.W. 1045 (Tenn.
1896)). The beneficiary's mere expectancy "is analogous to a donee's interest in a future gift or a legatee's
interest in a will before the testator's death." Id. "In such a case ‘the designation' of the beneficiary ‘is in
the nature of an inchoate or unexecuted gift, revocable at any moment by the donor, and remaining wholly
under his control.'" Id. (quoting Winn, 33 S.W. at 1045-46). Thus, "a beneficiary's expectancy does not
constitute a marital asset in a divorce action." Id. (citing Bell v. Bell, 896 S.W.2d 559, 562, 564 (Tenn. Ct.
App. 1994)).
 -7-
 agreement. Id. at 456. Thirty-four days after the divorce, the husband died, and the wife
was still the named beneficiary under the policy. Id. at 457. The sister of the decedent
brought suit on behalf of two children against the ex-wife. Id. The trial judge awarded the
policy proceeds to the ex-wife "as named beneficiary," but the majority of the Court of
Appeals reversed. Id. "The majority regarded as significant the language of the settlement
agreement that ‘each party relinquishes to the other any rights or claims not provided for
herein,' and the fact that wife was represented by counsel at the time of the execution of
the agreement and husband was not[.]" Id. The majority reasoned that "a layman reading
a property settlement agreement with the same or similar language . . . would believe . . .
that each spouse had in fact relinquished all rights that he or she had in the property of the
other." Id. Thus, the Court of Appeals held that "where the property settlement agreement
and resulting decree of divorce generally divest a former spouse of all rights or claims not
provided for herein," and the former spouse suffers an untimely death a short time later
without changing the beneficiary, "there is a rebuttable presumption created that all of the
former spouse's rights in the proceeds of any life insurance have been terminated." Id.
However, the dissenting judge concluded that "being the beneficiary of a husband's life
insurance was not a right or claim arising out of the marital relationship and thus was not
‘relinquished' or ‘waived' by the property settlement agreement and therefore the proceeds
of the policy passed to the wife by insurance contract law." Id.

 On appeal, the Supreme Court framed the issue as "whether a property settlement
agreement incorporated in a divorce decree, wherein wife released husband from all claims
arising out of the marital relationship and waived any other rights not provided for therein,
should be construed as effecting a change in beneficiary of husband's life insurance,"
where she remained the named beneficiary upon his death thirty-four days after the divorce.
Id. at 456-57. The Supreme Court explained that the issue was "one of first impression in
this State and there is respectable authority in other jurisdictions that supports either result."
Id. at 458. However, the Supreme Court concluded that the Court of Appeals dissent had
expressed "the better view." Id. at 457. The Supreme Court quoted "the essence of that
opinion," which stated:

 Being a beneficiary of the life insurance of her ex-husband was not a
 ‘property right', a result of an ‘obligation to support a wife', a ‘right', or a
 ‘claim' which was waived and relinquished by the property settlement
 agreement. The husband was under no duty by law or contract to have life
 insurance in the first place or to designate the defendant as the beneficiary of
 it; he could have changed the beneficiary at any time without encountering
 any of the defendant's rights; she simply had no claim with respect to the life
 insurance. Therefore the terms of the property settlement agreement do not
 affect the life insurance policy at all. This is the majority view and the better
 view in my opinion. See 46 C.J.S., Insurance, s 1160, and Couch on
 Insurance 2d. s 27.111.
 The majority opinion however does not stand entirely on what it calls
 -8-
 the ‘broad and general' provisions of the release. The majority creates a
 rebuttable presumption out of the release and the untimely death of the
 insured a ‘short time' later and the lack of a ‘reasonable' time within which
 to change the beneficiary. Even under that test the Trial Judge should be
 affirmed. Thirty-four days is not a ‘short time' and is a ‘reasonable' time
 within which to change a beneficiary of life insurance, or at least to make a
 start at it.
 Furthermore, in my opinion that period of time after the divorce is
 granted should not be given the significance that it apparently is by the
 majority. A divorce does not come as an earthquake, without warning, to
 suddenly break apart a marriage where one day the parties are happy and the
 next day headed for divorce. A divorce is generally the result of a long
 smouldering process of discontent and disenchantment. The parties have
 months in which to contemplate and consider all the ramifications of the
 divorce.... In such a situation the number of days after the divorce is granted
 is far less significant and should not give rise to a presumption that the
 deceased intended to change the beneficiary of his life insurance.

Id. at 457-58. After discussing caselaw from other jurisdictions addressing the issue, the
Supreme Court concluded by stating, "It is our view that the property settlement agreement
had no force and effect whatever upon the life insurance policy and neither the agreement
nor the divorce terminated wife's status as named beneficiary in the policy or her right to
receive the proceeds." Id. at 459.

 The following year, the Tennessee Supreme Court described its holding in Bowers
as a "refus[al] to apply a rule of presumed revocation, either conclusive or rebuttable, to an
insurance policy designation where the decedent continued his former wife as beneficiary."
In re Est. of Perigen, 653 S.W.2d 717, 720 (Tenn. 1983). The Court noted that Bowers
had involved a property settlement agreement that "in rather sweeping terms purported to
release all claims which either party had against the other, but despite this fact the Court
held" that it "‘had no force and effect whatever upon the life insurance policy and neither
the agreement nor the divorce terminated wife's status as named beneficiary in the policy
or her right to receive the proceeds.'" Id. (quoting Bowers, 637 S.W.2d at 459). Simply
put, "[Bowers] held that the divorce and property settlement had no effect upon the
beneficiary designation, and the former wife was permitted to receive the insurance
proceeds." Id. (citing Bowers, 637 S.W.2d at 459).

 This Court applied the Bowers holding in Mathews v. Lawrence, 703 S.W.2d 156,
157 (Tenn. Ct. App. 1985), an interpleader suit filed by the State Treasurer to determine
the right to receive accumulated retirement contributions held for the benefit of a deceased
husband. The two defendants were the former wife of the deceased and the decedent's
estate. Id. Prior to his divorce, the decedent had designated his wife as the person to

 -9-
 receive the accumulated contributions upon his death.4 Id. However, the divorce decree
incorporated a final property settlement that provided:

 Each party hereto does hereby release and discharge the other from all
 obligations of support and from all other claims, rights, and duties, except as
 hereinabove set out, arising or growing out of said marital relationship,
 including alimony, etc., and said parties mutually agree that each party hereto
 may freely sale (sic), or otherwise dispose of his or her property by gift, deed,
 or last will and testament; and each party is, by these presents, hereby forever
 barred from any and all claims of rights against the other party, or the
 property or estate of other party by way of inheritance, descent, distribution,
 homestead, allowance of one year's support, and other rights or claims
 whatever in or to the estate of the other, whether real, personal, or mixed, and
 whether now owned or hereinafter acquired.

Id. This Court explained that the accumulated contributions, subject to withdrawal by the
husband, were "marital property" and were "subject to consideration in the division of
marital property." Id. at 158. "However, the designation of [the wife] as the survivor to
whom refund of contributions should be made created an individual interest which entitled
her to payment unless the designation should be revoked." Id. The estate argued that the
property settlement agreement "expressly waived" the wife's right to the refund of
contributions, as it stated, "[E]ach party is ... barred from ... claims ... to the property or
estate of the other by way of inheritance ... and other rights or claims ... to the estate of the
other[.]" Id. Still, the Court explained that her right as designee of the refund was not a
right of inheritance or a claim against the estate of the deceased. Id. It was a contractual
right against the Treasurer of the State, although it "was subject to termination by
cancellation of the designation during the lifetime of deceased." Id. Ultimately, we
concluded that the ex-wife's status "as designated beneficiary of refund of contributions is
not materially different from the position of a designated beneficiary of an insurance
policy," so Bowers was "deemed to be controlling." Id. We affirmed the trial court's
determination that the former wife was entitled to the fund. Id. at 157-58.

 In Teachers Insurance & Annuity Association v. Harris, 709 S.W.2d 592, 593
(Tenn. Ct. App. 1985), TIAA filed an interpleader action to determine the primary
beneficiary of two retirement and annuity contracts, where the decedent's first wife was
the named beneficiary and his second wife was his surviving widow. The divorce decree
"purportedly settled all claims for property between the decedent and his first wife," so the
second wife argued that the first wife had "waived her interests in the proceeds from the

 4
 Upon the death of a member prior to retirement, his or her accumulated retirement contributions
were to be paid to his or her estate or to the person he or she nominated by written designation. Mathews,
703 S.W.2d at 157. Thus, the funds at issue were not a retirement benefit but a refund of contributions to
a retirement fund because no retirement benefits were paid. Id.
 - 10 -
 annuity contracts" in the divorce decree. Id. at 593-94. The decree provided:

 It is agreed by the parties that this Agreement shall be a final settlement of
 the property rights of the respective parties, and it is a full discharge of
 Husband from all other claims arising out of the marital relationship, that
 each party hereby waives and relinquishes to the other party all rights or
 claims which he or she may have or hereafter acquire under the law of any
 jurisdiction to the other's property, including without limitation, dower,
 curtesy, statutory allowance, homestead rights, rights to take against the will
 of the other, inheritance, descent or distribution, and the right to act as
 administrator or executor of the other's estate. This instrument applies to all
 property now owned by the parties either jointly or individually, or any
 property which either of them may acquire in the future.5

Id. at 595. The trial court held that the first wife was entitled to the proceeds, and this
Court affirmed. Id. at 594, 596. We concluded that "the provisions of the divorce decree
do not waive any rights [the first wife] had as the designated beneficiary on these annuity
agreements." Id. at 595. We explained,

 In Bowers v. Bowers, 637 S.W.2d 456 (Tenn. 1982), our Supreme
 Court had the identical question concerning a life insurance contract. In that
 case the divorce decree said, "Each party relinquishes to the other any right
 to claims not provided for herein." Nevertheless, the Supreme Court held
 that the property settlement agreement had no force and effect whatever upon
 the life insurance policy and neither the agreement nor the divorce terminated
 the wife's status as named beneficiary or her right to receive the proceeds.
 Although the appellant in this case argues that there is a difference between
 annuity agreements and a life insurance policy, we are unable to see any
 distinction. We think this case is governed by the decision in Bowers.
 Therefore, considering the provision of the divorce decree, we think that the
 question presented to the Chancellor in the court below was a matter of law
 which is resolved against the appellant's contention by the decision in

 5
 Notably, the provision at issue in Harris was nearly identical to the thirteenth paragraph of the
marital dissolution agreement executed by Mr. Birdwell and Ms. O'Dell in this case, which provides:
 It is understood and agreed between the parties that this Agreement is intended to be a final
 settlement of all property rights of the respective parties hereto and is a discharge from all
 of the claims arising out of their marital relationship, and that each hereby waives and
 relinquishes to the other all rights or claims which each may have or hereafter acquire under
 the law of any jurisdiction of the other's property, including without limitation, dower,
 curtsey, statutory allowance, homestead rights, right to take against the will of the other,
 inheritance, descent or distribution or right to as Administrator or Executor of the other's
 estate, and this Agreement applies to all property now owned by the Wife and Husband, or
 any property that either of them may acquire in the future.
 - 11 -
 Bowers.

Id. The former wife, as the designated beneficiary, was entitled to the funds. Id.

 The Tennessee Supreme Court applied Bowers again in Mathews v. Harris, 713
S.W.2d 311 (Tenn. 1986). The issue in that case was whether, under the Tennessee
Consolidated Retirement System statutes, the decedent's first wife, as designated
beneficiary of the retirement benefits, was entitled to priority over a non-designated
surviving spouse. Id. at 312. The husband became a member of the retirement system in
1947 and designated his then-wife as beneficiary. Id. In 1965, he executed another form
again naming his wife as beneficiary. Id. They divorced in 1982, and she remained the
designated beneficiary thereafter. Id. However, "a detailed property settlement agreement
had been entered into and incorporated into the final decree," and it "contained a complete
waiver of any rights of either spouse against the other." Id. at 313. Thus, the second wife
argued that "the terms and provisions of the property settlement agreement had the effect
of vitiating the 1965 designation of beneficiary." Id. "On the authority of Bowers," the
trial court held that "the previous designation was not affected by the subsequent divorce
proceedings which made no reference to it." Id. The Tennessee Supreme Court stated that
it "concur[red] in that conclusion for the reasons stated in that opinion." Id. Just as in the
case of the beneficiary designation on a life insurance policy, "the previous designation
was not affected by the subsequent divorce proceedings which made no reference to it."
Id.; see also Mathews v. Burkeens, 763 S.W.2d 739, 741 (Tenn. 1988) (citing Mathews v.
Harris, 713 S.W.2d at 311).

 Similar issues arose in Sun Life Assurance Co. of Canada v. Hicks, 844 S.W.2d 652,
653 (Tenn. Ct. App. 1992), where the husband's employer maintained a group life
insurance policy for its employees, and he had initially named his mother as beneficiary
but later changed it to name his wife. When the parties later divorced, the final decree "did
not make any disposition of the right to any life insurance then carried by the [husband]."
Id. His employer changed the group insurance plan and subsequently supplied a "survey"
form to all employees regarding various information, on which the husband listed his
mother as the beneficiary of his life insurance. Id. However, he did not follow the proper
procedure to actually change the beneficiary designation with the plan administrator. Id.
at 654. The trial court acknowledged that the husband did not follow the correct procedure
but nevertheless awarded the proceeds to his mother, concluding that by listing his mother
on the survey form he had expressed his intent on the matter and done everything
reasonably possible to comply with the policy terms, establishing substantial compliance.
Id. This Court reversed. At the outset, we cited Bowers for the rule that "[t]here is no
presumption that an ex-spouse is removed as a beneficiary from an insurance policy by the
mere fact that the parties have been divorced." Id. (citing Bowers, 637 S.W.2d at 456).
We also pointed out that the final decree of divorce "in no way addressed Wife's rights
under this life insurance policy." Id. As a result, we examined the trial court's holding
that the husband had substantially complied with the terms of the policy for changing the
 - 12 -
 beneficiary by naming his mother as the beneficiary on the survey form. Id. We explained
that "Tennessee has cast its lot as a ‘substantial compliance' state as regards the issue of a
change in beneficiary of an insurance policy." Id. Appellate court decisions on the issue
were "fact specific" and had "reached different results."6 Id. However, we concluded that
this particular husband did not substantially comply with the requirements set forth by the
insurance carrier, as he did not take all reasonable steps possible to meet the conditions of
the policy. Id. He had twice before executed the proper cards to name his beneficiary, and
there was no proof that the employer survey form was ever contemplated to be used to
change a beneficiary. Id. at 654-55. The employee simply did not "avail himself of the
use of the change of beneficiary card" as he had in the past. Id. at 655. As a result, the
trial court erred in finding substantial compliance, and the wife was entitled to the proceeds
of the policy. Id.

 We briefly discussed the holding of Bowers in Deckard v. Middleton, No. 01-A-01-
9502-CH0005, 1995 WL 428677, at *1 (Tenn. Ct. App. July 21, 1995), recognizing that in
Bowers "our Supreme Court held that a property settlement does not extinguish a former
wife's rights as named beneficiary of a life insurance policy." We also noted that "[t]his
rule [was] followed" in four other cases cited on appeal. Id. However, this Court deemed
Bowers and the other cases "inapposite to the facts of this case" because the beneficiary
designation at issue did not designate anyone by name, it simply listed "the participant's
spouse." Id. Because the beneficiary form "took effect at the time of death," the funds
went to the surviving spouse. Id.

 In Travelers Ins. Co. v. Webb, No. 01-A-01-9508-CH00379, 1996 WL 23491, at *1
(Tenn. Ct. App. Jan. 24, 1996), we considered another interpleader action, this time
involving a dispute between two wives over the proceeds of a life insurance policy the
husband had obtained through his employer. Again, the former wife was the designated

 6
 On the issue of substantial compliance, we explained,

 A mere unexecuted intention to change the beneficiary is not sufficient.... On the principle
 that equity regards as done that which ought to be done, the courts will give effect to the
 intention of insured by holding that the change of beneficiary has been accomplished where
 he has done all that he could to comply with the provisions of the policy, as where he sent
 a proper written notice or request to the home office of the company but was unable to send
 the policy by reason of circumstances beyond his control, as where it has been lost, or was
 in the possession of another person who refused to surrender it or was otherwise
 inaccessible, or where he sent both the policy and a proper written notice or request and all
 that remained to be done were certain formal and ministerial acts on the part of the
 company, such as the indorsement of the change of the policy, and these acts were either
 not done at all or were done after the death of insured. Of course the rule is not applicable
 where insured has not done all that he reasonably could to meet the conditions of the policy.

Sun Life Assur. Co. of Canada, 844 S.W.2d at 654 (quoting Cronbach v. Aetna Life Ins. Co., 284
S.W. 72, 73 (Tenn. 1926)).
 - 13 -
 beneficiary at his death. Id. We held that the trial court "correctly applied Tennessee law"
in holding that "the person entitled to a policy's benefits is the person designated as the
beneficiary in the insurance contract." Id. at *2. As the chancellor correctly stated, "An
insurance contract-insurance policy is a contract between the policy owner and the
insurance company, and the policy owner can designate the beneficiary he or she desires."
Id. In the Webb case, there were no disputed facts, as the husband had designated the
beneficiary and never changed it or took steps to change it, so summary judgment was
appropriate. Id. The second wife argued on appeal that the "divorce destroyed [the first
wife's] rights as the named beneficiary." Id. at *3. However, we deemed this argument
"without foundation," with the following explanation:

 The courts of this state have consistently held that "[t]here is no presumption
 that an ex-spouse is removed as a beneficiary from an insurance policy by
 the mere fact that the parties have been divorced." Sun Life Assurance Co.
 v. Hicks, 844 S.W.2d 652, 654 (Tenn. App. 1992). The Tennessee Supreme
 Court held that neither a divorce nor a property settlement agreement has any
 impact upon the beneficiary designation of an insurance policy. Bowers v.
 Bowers, 637 S.W.2d 456, 459 (Tenn. 1982). Being a beneficiary of an
 insurance policy is not a "right or claim arising out of the marital relationship
 and thus [is] not ‘relinquished' or ‘waived' by the property settlement
 agreement and therefore the proceeds of the policy pass [ ] [to the designated
 beneficiary] by insurance contract law." Id. at 457. Thus, neither the divorce
 nor the property settlement agreement deprived [the first wife] of her rights
 as the named beneficiary of the policy.7

Id.

 We discussed Bowers again in Claiborne v. Claiborne, No. 03A01-9708-CH-

 7
 Addressing other arguments, the Webb Court also explained that "[the decedent's] will did not
affect his life insurance contract." 1996 WL 23491, at *2. The second wife had argued that the decedent's
expression in his will that he wanted her to have the insurance proceeds "amended the insurance contract."
Id. However, "[w]hen there is no attempt to change the beneficiary according to the procedures set forth
in the policy, the law of this state provides that a constructive trust does not arise, requiring distribution
according to the terms of the will, even though the testator clearly indicated in his will that he wanted the
insurance proceeds to benefit an individual other than the named beneficiary." Id. (citing Stoker v.
Compton, 643 S.W.2d 895, 898 (Tenn. App. 1981)). "[T]he language in a will does not operate to deprive
the named beneficiary of her rights to the policy proceeds." Id. (citing Cook v. Cook, 521 S.W.2d 808, 813
(Tenn. 1975)).
 We also rejected the second wife's argument that there was a factual dispute regarding the issue of
substantial compliance. Id. at *3. She claimed that the husband's change of the beneficiary on a different
policy and his oral statements to family were "sufficient to invoke the doctrine of substantial compliance."
Id. However, these arguments "demonstrate[d] a misunderstanding of the doctrine of substantial
compliance." Id. The decedent made no attempt to comply with the insurer's requirements for changing
the beneficiary of this policy, so there was no substantial compliance. Id. at *4.
 - 14 -
 00353, 1998 WL 259893, at *1 (Tenn. Ct. App. May 14, 1998), which involved a dispute
over life insurance proceeds between an ex-wife and the decedent's estate. At the time of
the decedent's divorce, his wife was designated as beneficiary of his life insurance policy.
Id. The divorce decree required the husband to pay $36,000 to the wife over six years to
equalize the division of marital property, and he was ordered to maintain a life insurance
policy with the wife named as the irrevocable beneficiary for a minimum face value of
$50,000 for the first three years during which his obligation was pending and $25,000 for
the remaining three years of the obligation. Id. After the divorce, he left his existing policy
"as it was," with the wife designated as the beneficiary, and the face amount of the policy
at $140,000. Id. He died after having paid $12,000 of the obligation. Id. His daughter,
as executrix of his estate, filed the lawsuit seeking a declaratory judgment that the ex-wife
was entitled to receive only $50,000 of the life insurance proceeds. Id. Applying Bowers,
the trial court found that the ex-wife was entitled to the full amount of the policy because
"the settlement agreement incorporated in the divorce decree did not alter the rights of the
named beneficiary under the insurance policy." Id. at *2. This Court affirmed. Id. To
begin, we noted that the divorce judgment required the husband to maintain an insurance
policy with a minimum value of $50,000, but it did not "purport to affect the provisions of
any existing insurance contract." Id. "Notwithstanding the absence of any language in the
trial court's judgment pertaining to the existing policy of insurance," the estate argued on
appeal that "the intent of the parties at the time their agreement was reached concerning
life insurance, and as incorporated into the final judgment of divorce, modified Wife's
rights to the entire proceeds of the policy." Id. We explained that "Tennessee courts have
considered the effect of a divorce property settlement agreement on insurance beneficiary
designations," beginning with Bowers. Id. After a discussion of the relevant caselaw, we
stated that the ex-wife in that case "[stood] to reap a windfall unless there is language in
the final judgment of divorce which can reasonably be read as divesting the former spouse
of her contractual rights as the named beneficiary under the policy." Id. at *3. However,
we concluded that the terms of the divorce decree were "not at odds with the contract of
insurance" and did not cause the wife "to forfeit the rights of a beneficiary under the
insurance policy." Id. The "fair meaning of the divorce judgment" was that the husband
could have reduced the insurance coverage to the minimum of $50,000, and the decision
to maintain insurance above that amount was voluntary on his part. Id. We quoted "with
approval" from the trial court's decision:

 The language in the judgment is that he maintain a minimum face value of
 fifty thousand dollars. Beyond that the matter was voluntary so that to the
 extent voluntariness controls the situation we think he voluntarily did
 maintain the larger amount of coverage.
 That's consistent with the discussion of the Ohio case in the Bowers
 case which indicates that divorce settlement language applying to other
 aspects of the marital relationship and settling those aspects of the property
 interest of the parties would not forfeit the rights of a beneficiary under an
 insurance policy.
 - 15 -
 Finally, in the Bowers case it is observed by the Court that the property
 settlement agreement had no force and effect whatever upon the life
 insurance policy and neither that agreement nor the divorce terminated the
 rights or status as a named beneficiary in the policy of the wife, or her right
 to receive proceeds. Now, that language doesn't totally apply here, but it
 does indicate this: that the parties in a divorce case that come to an
 agreement, and that was the situation here, are free to make such an
 agreement as they desire governing insurance, or let the matter stand and be
 governed by the policy as is.

Id. at *3-4. We likewise found nothing inconsistent between the terms of the divorce
judgment and the wife remaining the policy beneficiary in the full amount of the policy.
Id. at *4. Therefore, the decision of the trial court was affirmed.8 Id.

 This Court considered facts more similar to those before us in In re Estate of
Williams, No. M2000-02434-COA-R3-CV, 2003 WL 1961805 (Tenn. Ct. App. Apr. 28,
2003) perm. app. denied (Tenn. Oct. 6, 2003). That case involved a dispute over a
husband's sizeable estate following his untimely death shortly after his divorce. Id. At
issue were several annuity contracts that named his ex-wife as the beneficiary. Id. The
decedent's estate filed a complaint for declaratory judgment, asserting that the annuities
belonged to the estate because of language in the parties' marital dissolution agreement.
Id. Notably, the annuities "had been awarded to [the husband] in the final divorce decree,
but [the wife] was still named as the beneficiary at his death." Id. at *17. Thus, the estate
argued that Bowers was distinguishable because in Bowers the divorce decree "did not
expressly address the life insurance policy at issue," but "the Williams MDA expressly
referred to the annuity contract by name and number." Id. at *18. Despite this argument,
the trial court could not conclude that "this distinction would cause the Supreme Court to
carve out an exception to the Bowers rule of law." Id. Relying on "the controlling authority
of Bowers," the trial court granted the wife summary judgment, awarding her the annuities
as the named beneficiary thereof. Id.

 On appeal, the estate argued that "the MDA specifically awarded Mr. Williams the
annuity contracts at issue and, therefore, the trial court should have merely implemented

 8
 We note that "Tennessee courts have utilized equitable grounds to protect persons legally
mandated to be listed as beneficiaries of a life insurance policy." Holt v. Holt, 995 S.W.2d 68, 72 (Tenn.
1999) (emphasis added). Thus, "it is clear under Tennessee law that an enforceable agreement, such as a
marital dissolution agreement, which mandates that an individual be listed as a beneficiary of a life
insurance policy existing at the time of the agreement vests in that individual an equitable interest in the
designated policy." Id. A beneficiary's "‘mere expectancy' may be converted into a vested interest in the
wife where the husband is required by a divorce decree to keep a life insurance policy in effect naming
certain beneficiaries and is denied the right to change the beneficiary by such court order." Bell v. Bell, 896
S.W.2d 559, 562 (Tenn. Ct. App. 1994); see also Hughes v. Hughes, No. E2016-00561-COA-R3-CV, 2017
WL 57163, at *2 (Tenn. Ct. App. Jan. 5, 2017).
 - 16 -
 and enforced the MDA." Id. at *17. We explained that the question of the right to the
annuity death benefit was a question of law, and like the trial court, we also deemed Bowers
controlling. Id. at *17-19. We explained:

 In Bowers, the Supreme Court defined the single issue in that case as
 "whether a property settlement agreement incorporated in a divorce decree,
 wherein wife released husband from all claims should be construed as
 effecting a change in beneficiary of husband's life insurance, where wife was
 still the named beneficiary under the policy at the date of husband's death,
 thirty-four days after the divorce." 637 S.W.2d at 456. On that issue, the
 Court held that "the property settlement agreement had no force and effect
 whatever upon the life insurance policy and neither the agreement nor the
 divorce terminated wife's status as named beneficiary in the policy or her
 right to receive the proceeds." 637 S.W.2d at 459.
 In Tennessee a change of beneficiary must be accomplished in
 substantial compliance with the terms of the insurance contract. Sun Life
 Assurance Co. v. Hicks, 844 S.W.2d 652, 654 (Tenn. Ct. App. 1992).
 Consequently, our courts have held that a provision in a will attempting to
 change the beneficiary cannot vary the provisions of the contract.

 [T]he language in a will does not operate to deprive the named
 beneficiary of her rights to the policy proceeds. Cook v. Cook,
 521 S.W.2d 808, 813 (Tenn. 1975). When there is no attempt
 to change the beneficiary according to the procedures set forth
 in the policy, the law of this state provides that a constructive
 trust does not arise, requiring distribution according to the
 terms of the will, even though the testator clearly indicated in
 his will that he wanted the insurance proceeds to benefit an
 individual other than the named beneficiary. Stoker v.
 Compton, 643 S.W.2d 895, 898 (Tenn. App. 1981).

 Travelers Ins. Co. v. Webb., No. 01-A-01-9508-CH-00379, 1996 Tenn. App.
 LEXIS 44, at *6 (Tenn. Ct. App. Jan. 24, 1996)[].
 It is well settled that divorce itself does not create a presumption that
 a former spouse is removed as a beneficiary. Sun Life Assurance Co., 844
 S.W.2d at 654. Bowers and its progeny established that a property settlement
 agreement also does not affect a designation of beneficiary. The same
 principles have been applied to a designation of beneficiary in an annuity
 contract, Teachers Ins. & Annuity Assoc. v. Harris, 709 S.W.2d 592, 595
 (Tenn. Ct. App. 1985), because there is no relevant distinction between an
 insurance contract and an annuity contract.
 The Court's conclusion in Bowers rested in part upon its
 determination that being a beneficiary was not a right or claim arising out of
 - 17 -
 the marital relationship and, therefore, was not included in the property
 settlement's language waiving or relinquishing such rights and claims. 637
 S.W.2d at 457-58. However, the Court also explicitly found that a property
 settlement agreement has "no force and effect whatever" upon a life
 insurance policy, indicating its reliance on legal requirements for changing a
 beneficiary. Id. at 459. The Estate argues that Bowers should not be applied
 herein because of the language of the MDA at issue. The Williams MDA
 listed, along with other assets, the three annuities, giving a value to each and
 awarding each to Mr. Williams "free of any claim by Wife." The Estate
 argues that the MDA explicitly grants the annuities to Mr. Williams and no
 further search for Mr. Williams's intent is required. It further asserts that a
 constructive trust should have been granted to prevent unjust enrichment to
 Kathryn Williams "as a matter of equity and good conscience."
 There is nothing about the language in the MDA to make inapplicable
 the principles discussed above. Although Bowers interpreted general
 language waiving claims arising from the marriage, and Ms. Williams agreed
 to waive any claim to the annuities themselves, the fact remains that no
 attempt was made to change the beneficiary in compliance with the annuity
 contract provisions. If the explicit language of a decedent's will expressing
 an intent contrary to the designation of beneficiary cannot effectuate a change
 of beneficiary, certainly the "free of claim" language does not. We do not
 disagree that the MDA clearly awarded the annuities to Mr. Williams. As
 the owner, he was free to name any beneficiary he chose, including Ms.
 Williams, whether he was married to her or not.

Id. at *18-19. Thus, we affirmed the grant of summary judgment to the ex-wife and the
resulting award to her of the proceeds. Id. at *19.

 Despite this line of cases consistently ruling in favor of named beneficiaries, this
Court reached the opposite result in Lunsford v. Lunsford, No. M2004-00662-COA-R3-
CV, 2005 WL 2572389 (Tenn. Ct. App. Oct. 12, 2005). In Lunsford, the husband
participated in his employer's retirement fund and designated his wife as the primary
beneficiary of its pre-retirement death benefit. Id. at *1. His three children from a prior
marriage were named as contingent beneficiaries. Id. When the parties divorced, they
executed a marital dissolution agreement that provided:

 Each spouse hereby further waives and releases except as otherwise provided
 herein, any right, title and interest which he or she may have now, or in the
 future, to any retirement payment or annuity by virtue of his or her being the
 spouse of the other party, and by virtue of such other party's employment, or
 by virtue of any other retirement program, plan or pension system which may
 have included the other party in the past, or which may include such other
 party now, or which may include the other party in the future. To this end
 - 18 -
 both parties declare that it is each's (sic) intent that this provision have the
 same force and effect as if he or she had signed any waiver forms releasing
 his or her aforementioned interest, but each further agrees to execute
 whatever documents may be required in this regard in the future, as
 necessary, to accomplish the purposes heretofore stated.

Id. However, the ex-wife remained the designated beneficiary when the husband died. Id.
The personal representative of the decedent's estate filed a petition in the divorce action
seeking to enforce the marital dissolution agreement and divest the wife of any interest in
the death benefit. Id. The trial court granted the petition and entered a qualified domestic
relations order directing that the proceeds be paid to the children as contingent
beneficiaries, finding that "it was the intent of the parties, as set forth in the Marital
Dissolution Agreement, that they each be divested of any right, title and interest that they
may have in the retirement or pension benefits of the other." Id. at *2. On appeal, this
Court affirmed, "[b]ecause of the specific language of the marital dissolution agreement."
Id. at *1. We concluded that the particular language used in this marital dissolution
agreement "differentiates this case from other cited cases," such as Bowers. Id. at *3. To
that end, we explained,

 We recognize that it is settled law in Tennessee that the designation
 of beneficiaries on life insurance policies and the death benefits in annuity
 agreements are matters of contract between the participant and the company
 or organization issuing the policy of life insurance or funding the annuity
 agreement. Bowers v. Bowers, 637 S.W.2d 456 (Tenn. 1982); Sun Life
 Assurance Co. v. Hicks, 844 S.W.2d 652 (Tenn. Ct. App. 1992); Teachers
 Ins. & Annuity Assoc. v. Harris, 797 S.W.2d 592 (Tenn. Ct. App. 1985); In
 re: Estate of James H. Williams, No. M2000-02434-COA-R3-CV (Tenn. Ct.
 App. April 28, 2003) (Tenn. R. App. P. 11 application denied October 6,
 2003). As such, the beneficiary may be changed only by substantially
 complying with the contract provisions. Sun Life Assurance Co. v. Hicks,
 844 S.W.2d at 654; Massachusetts Mutual Life Insurance Company v. Henry,
 638 S.W.2d 410 (Tenn. App. 1982). It cannot be accomplished by will, Cook
 v. Cook, 521 S.W.2d 808 (Tenn. 1975); Stoker v. Compton, 643 S.W.2d 895
 (Tenn. App. 1981), by completing a survey conducted by an employer, Sun
 Life Assurance Co. v. Hicks, supra., by a decree of divorce, Bowers v.
 Bowers, supra., or a marital dissolution agreement. Teachers Ins. & Annuity
 Assoc. v. Harris, 797 S.W.2d at 595.
 We further recognize that, analytically, there would seem to be no
 practical distinction between a death benefit in an annuity agreement and the
 death benefit in a retirement plan and none has been propounded to us.
 Consequently, the rationale contained in the cases we have cited apply to the
 situation before the court. . . . According to the contract between Robert W.
 Lunsford and the YMCA Retirement Fund, Tina Lunsford was the
 - 19 -
 beneficiary of his pre-retirement death benefit at the time of his death.
 The foregoing conclusion does not, however, end the inquiry before
 us. In the present case, the marital dissolution agreement provided that the
 appellant waived and released any right, title and interest which she had "to
 any retirement payment or annuity" by virtue of Robert Lunsford's
 employment. The agreement further provided that this waiver provision
 would have the "same force and effect as if ... she had signed any waiver
 forms releasing ... her aforementioned interest." Finally, Tina Lunsford
 agreed "to execute whatever documents may be required in this regard in the
 future, as necessary, to accomplish the purposes heretofore stated."
 (emphasis added). It is this continuing duty to execute whatever documents
 that may be required to accomplish the purpose and intent of the marital
 dissolution agreement that differentiates this case from other cited cases. At
 the time of his death, Robert Lunsford clearly had a contractual right to
 require the appellant to execute any document that might be required to
 effectuate her waiver and release of any interest she might have in retirement
 or annuity benefits. Following his death, Mr. Lunsford's personal
 representative had the right to enforce this contractual provision in his behalf.
 Since the trial court could have required the appellant to execute a waiver
 and release of Mr. Lunsford's retirement plan death benefit, it was not error
 to divest the appellant of any interest she might have in the benefit and award
 it to the contingent beneficiaries by way of a QDRO.

Id. at *2-3 (emphasis added). Thus, the decision of the trial court was affirmed. Id.

 In another case one year later, however, this Court declined another invitation to
distinguish Bowers on various grounds and instead found it controlling. In Shell v. Dills,
No. E2005-02636-COA-R3-CV, 2006 WL 3193659, at *1 (Tenn. Ct. App. Nov. 6, 2006),
we considered a dispute over death benefits from an employer's retirement plan, with the
dispute being between a former spouse who was the designated beneficiary and the
decedent's estate. The executor alleged that the decedent had inadvertently failed to
change the beneficiary designation following his divorce and that his new wife and child
were his "natural and testamentary" beneficiaries at his death. Id. The marital dissolution
agreement provided:

 It is mutually understood and agreed by and between the parties hereto that
 this is a complete and final Marital Dissolution Agreement between them;
 and that in the event a divorce is granted, neither of them will ever hereafter
 have any property claims whatsoever against the other, except as provided
 for and described herein.

Id. The trial court ruled in favor of the ex-wife as the named beneficiary, "stating the case
was controlled by the Supreme Court's decision in Bowers[.]" Id.
 - 20 -
 On appeal, we likewise explained that "[t]he body of case law applicable to this
controversy arose in the seminal case of Bowers[.]" Id. at *2. The estate argued that
"Bowers and its progeny [were] not dispositive, because in those cases, the MDA did not
contain an obligation of future conduct after the divorce, as found in this MDA." Id.
Specifically, the estate argued that when the ex-wife filled out the application to accept the
refund of the benefit contributions, "she violated her continuing obligation under the MDA
to refrain from making any property claims against the husband." Id. After a detailed
discussion of Bowers, TIAA v. Harris, and Mathews v. Harris, we returned to the estate's
contention that "this case should be distinguished from Bowers and its progeny because
the parties' MDA contains a ‘continuing' obligation of ‘future' conduct, and thus the wife's
contractual obligation to refrain from making a claim should be enforced such that she
could not accept a refund of contributions made by the husband." Id. at *3-4. We rejected
that argument as follows:

 Considering the language contained in the various agreements,
 however, this is a distinction without a difference. In Bowers, the parties
 simply agreed to relinquish "to the other any rights or claims not provided
 for herein," and the Court held that the beneficiary of a life insurance policy
 was not a "right" or a "claim" and did not necessarily arise out of the
 marriage relationship. In the Harris cases, the agreement was much more
 comprehensive, and stated that each party waived and relinquished "all rights
 or claims which he or she may have or hereafter acquire under the law of any
 jurisdiction to the other's property," and went on to state that it applied to
 property currently owned or later acquired. The Harris agreement explicitly
 contemplates current and future claims to current and future property. The
 Harris agreement states the same obligation that is in the MDA before us in
 a different way, i.e. the obligation to refrain from making future claims to the
 other's property.

Id. at *4.

 We also addressed the estate's separate argument that "the Bowers case was purely
an insurance claim, which is not the exact nature of the benefit here." Id. at *3. The estate
contended that "this case is distinguishable because it does not deal with a life insurance
policy or other benefit that is payable only upon death, but rather involves money that
decedent earned and contributed to the retirement plan." Id. at *4. We noted that TIAA v.
Harris, 709 S.W.2d at 592, had "involved a situation similar to the case before us regarding
a retirement annuity that provided death benefits," and this Court had deemed Bowers
controlling in that case as well, as "the divorce and the property settlement agreement had
no effect on the beneficiary designation, and there was no material distinction between
annuity agreements and a life insurance policy." Id. We further noted the Mathews v.
Harris decision of the Tennessee Supreme Court, 713 S.W.2d at 311, which relied on the
 - 21 -
 Bowers decision in a case involving the state employee retirement fund and accumulated
contributions. Id. at *3-4. Ultimately, we found "no basis to distinguish the precedents in
the Bowers and its progeny from the facts of this case," and therefore, we were "constrained
to affirm the Judgment of the Trial Court."9 Id. at *4.

 Ten years later, this Court again found Bowers distinguishable from the facts of a
case before us and decided to apply Lunsford instead. In Manning v. Manning, No. E2015-
02082-COA-R3-CV, 2016 WL 3640317, at *1 (Tenn. Ct. App. June 30, 2016), a husband
and wife had entered into a marital dissolution agreement stating that they agreed to waive
any interest in the other party's retirement account. The wife was listed as the beneficiary
on the husband's account, and he did not effectuate a change to his account thereafter. Id.
Upon his death, the former wife refused to sign documentation waiving her right to the
benefits, so the administrator of the estate filed suit, seeking a declaratory judgment that
she had waived any interest in the account pursuant to the marital dissolution agreement.
Id. It provided:

 Each party agrees to waive any interest he/she may have in the other party's
 retirement. Wife agrees to waive any interest she may have in Husband's
 Eaton Vance Growth Fund, bank accounts and certificates of deposit.
 ***
 Each of the parties shall execute, acknowledge and deliver any and all
 instruments and documents in writing which shall reasonably be required for
 purposes of effectuating the provisions and intent of this Marital Dissolution
 Agreement.

Id. During the wife's deposition, she acknowledged that "she agreed to execute any

 9
 Also in 2006, this Court considered a case with a very complicated procedural history and unique
facts involving a pension death benefit, in Wing v. Parchman, No. M2005-00273-COA-R3-CV, 2006 WL
940296 (Tenn. Ct. App. Apr. 11, 2006). There, a divorce decree originally awarded the wife "support" of
$230 as alimony once the husband retired. Id. at *1. The husband then retired and elected to receive a
definite sum of payments over 10 years, and he designated his daughter as the person to receive the
payments in the event of his death during that period. Id. However, a subsequent order required the husband
to pay the wife $230 as her share of the pension as "a division of property in lieu of" spousal support. Id.
The husband died, and a dispute arose between the wife and the daughter over the death benefit. Id. The
trial court acknowledged that "it would have been neater if the court had ordered Mr. Wing . . . to make his
wife the beneficiary" but it "did not do so" and "[n]obody dealt with the death benefit other than Mr. Wing,
so thus one must look at the intent of the court's order." Id. at *2. The trial court concluded that "this error
or oversight by the court or [wife's] attorney [was] not fatal," as "the intent of the court was to divide the
retirement benefits," the wife had a vested interest in them, and the husband's designation of the daughter
as death beneficiary was in contravention of the court's decree regarding property division. Id. at *1-2.
We affirmed, concluding that the pension benefit was marital property, the wife was awarded an identified
share of the monthly benefit, and the wife at the very least had an equitable claim to her marital share of
the monthly benefit, making a constructive trust appropriate. Id. at *3. We noted that "Tennessee courts
have utilized equitable grounds to protect persons legally mandated to be listed as beneficiary of a life
insurance policy" and likened the case to that situation. Id. (quoting Holt, 995 S.W.2d at 72).
 - 22 -
 waivers necessary to waive her claim to his retirement account." Id. However, she took
the position that the husband's failure to remove her as the named beneficiary indicated his
intent to gift the benefits to her. Id. The estate filed a motion for summary judgment,
supported by the wife's deposition testimony, alleging that the wife "agreed that she would
not have any claim to Husband's retirement" and "agreed that she would execute any
writings necessary to waive any claim that she had to the retirement of Husband." Id. at
*2. In response, the wife filed her own motion for summary judgment but again
acknowledged that she had "agreed that she would execute any document to waive any
claim as a beneficiary upon the same being presented to her." Id. The trial court held in
favor of the wife "as the named beneficiary," citing Bowers. Id.

 On appeal, the estate argued that "the facts presented in Bowers are inapposite to
the facts presented in this case and that this case is more closely aligned to the factual
scenarios presented in Lunsford and In re Estate of Ellis,10 No. M2012-00585-COA-R3-
CV, 2013 WL 1187419 (Tenn. Ct. App. March 20, 2013)[.]" Id. at *3. After discussing
the facts in Bowers regarding the life insurance policy at issue, the fact that Lunsford
involved a retirement account beneficiary, and In re Estate of Ellis, which involved funds
in jointly titled checking accounts, we concluded,

 10
 We note that In re Estate of Ellis involved a dispute over the ownership of funds in jointly titled
checking accounts at banking institutions after a divorce and the death of the husband. 2013 WL 1187419,
at *1. The marital dissolution agreement listed the two checking accounts as belonging to the husband, but
he had not notified the bank of the ownership change before he died. Id. at *2. On appeal, we explained
that a joint bank account with rights of survival is a binding contract between the joint owners of the
account, but contracts can be modified, so we deemed the marital dissolution agreement as "tantamount to
an amendment to their contract." Id. at *4. The marital dissolution agreement provided that the wife was
divested of her interest in the checking accounts, so that agreement superseded the joint tenancy designation
on the accounts. Id. Notably, however, this Court acknowledged that the ex-wife had cited "a series of
other cases" on appeal, including Bowers, Matthews v. Lawrence, and Estate of Williams, which had also
"involved an MDA or a property settlement agreement entered into in contemplation of divorce, and the
failure of the husband to make subsequent changes to the disposition of the disputed property prior to his
unexpected death." Id. at *5. We stated that "none of those cases involved a joint bank account and all of
them can be distinguished from the present one." Id. We explained that Bowers involved a life insurance
beneficiary designation, Mathews involved the beneficiary designation on a retirement account, and Estate
of Williams involved the beneficiary designation on annuities, and therefore, "[t]he primary difference
between the present case and the three we have just discussed involves the nature of the interests involved."
Id. at *5-6. We noted the joint checking accounts at issue in Estate of Ellis met the definition of marital
property, were appropriately included in the provisions of the marital dissolution agreement, and once that
agreement was approved by the trial court, "both parties obtain[ed] a vested interest in the property allocated
to them." Id. at *6. The wife argued that "the distinction our courts have drawn between joint bank accounts
and other assets (such as life insurance contracts) that serve as ‘will substitutes' is illogical and should not
be upheld," but we observed that the changes she advocated simply had not been "incorporated into existing
Tennessee law." Id.
 Just as the Estate of Ellis Court distinguished the Bowers line of cases involving beneficiary
designations due to the nature of the interests involved, we likewise deem Estate of Ellis distinguishable
from this case because it involved joint checking accounts.
 - 23 -
 The facts presented in Bowers are simply inapposite to the facts
 presented in this case. We agree with Administrator that this case is more
 closely aligned with the facts presented in Lunsford and to an extent, Ellis.
 Here, the MDA specifically addressed the divestment of Wife's interest in
 the retirement account at issue. An MDA incorporated into a final decree of
 divorce "is a contract which is binding on the parties." Stiel v. Stiel, 348
 S.W.3d 879, 885 (Tenn. Ct. App. 2011). Generally, once a contract is formed
 it cannot be modified without consent and additional consideration for the
 new terms. GuestHouse Intern., LLC v. Shoney's North America Corp., 330
 S.W.3d 166, 190 (Tenn. Ct. App. 2010). While Husband failed to remove
 Wife as the named beneficiary, his failure does not evidence intent to modify
 when Wife possessed continuing obligations to waive any right she may have
 held in the account and to execute any documents reasonably required for the
 purpose of effectuating the provisions in the MDA. The record is simply
 devoid of any evidence establishing a modification of the MDA.

Id. at *3-4. Thus, we reversed the decision of the trial court and remanded for entry of
summary judgment in favor of the estate. Id.

 Finally, we note this Court's more recent opinion on the matters before us in Voya
Retirement Ins. & Annuity Co. v. Johnson, No. M2016-00435-COA-R3-CV, 2017 WL
4864817 (Tenn. Ct. App. Oct. 27, 2017) perm. app. denied (Tenn. Feb. 14, 2018). Voya
was another interpleader action, in which the court was asked to determine the proper
beneficiary of death benefits from an employee's retirement plan. Id. at *1. The decedent's
former wife and his estate both demanded the payment from the plan administrator. Id.
The former wife was listed as the beneficiary on the retirement plan, but the estate argued
that the beneficiary designation had been revoked by the couple's marital dissolution
agreement. Id. The marital dissolution agreement had awarded the husband all right, title,
and interest in "all retirement that he may have through his employment with the Metro
Government." Id. The trial court ruled that the marital dissolution agreement revoked the
beneficiary designation, so the benefits were payable to the estate. Id. The ex-wife
appealed, arguing that "the MDA could not revoke the beneficiary designation in the
[retirement] Plan." Id. Thus, the issue before us was whether the marital dissolution
agreement should be construed as a revocation of the previous beneficiary designation. Id.
at *2. We ultimately concluded that "the marital dissolution agreement did not revoke the
previous beneficiary designation." Id. at *1. We deem it appropriate to quote our thorough
discussion of the applicable principles:

 Mr. Leary designated Ms. Johnson as his sole beneficiary and "failed
 to amend the beneficiary designation" after his divorce. But the chancery
 court ruled that the MDA revoked his beneficiary designation and denied Ms.
 Johnson's motion for judgment on the pleadings. We conclude that the
 chancery court erred in its application of Tennessee law to the undisputed
 - 24 -
 facts. As explained below, a beneficiary designation in a retirement plan may
only be changed as provided in the plan. The MetroMax Plan required the
plan participant to send a written request to the plan administrator to amend
or revoke a beneficiary designation. Although the MDA is in writing, the
language therein cannot be reasonably interpreted as a revocation of Mr.
Leary's beneficiary designation. And Mr. Leary did not send the MDA to
the plan administrator.
 Our supreme court considered whether a property settlement
agreement in a divorce proceeding could be construed as a revocation of a
beneficiary designation in a life insurance policy in the seminal case of
Bowers v. Bowers, 637 S.W.2d 456, 456-57 (Tenn. 1982). The Bowers court
held that the property settlement agreement "had no force and effect
whatever" on the husband's previous beneficiary designation. Id. at 459.
And "neither the agreement nor the divorce terminated wife's status as
named beneficiary in the policy or her right to receive the proceeds." Id. The
Bowers court reasoned that a beneficiary's right to receive life insurance
proceeds was governed by the terms of the insurance contract. Id. at 457-58.
 Since Bowers, our courts have consistently looked to the terms of the
relevant insurance contract to determine whether a purported change of
beneficiary designation was effective. See In re Estate of Williams, No.
M2000-02434-COA-R3-CV, 2003 WL 1961805, at *19 (Tenn. Ct. App.
Apr. 28, 2003); Travelers Ins. Co. v. Webb, No. 01-A-01-9508-CH00379,
94-2051-III, 1996 WL 23491, at *3 (Tenn. Ct. App. Jan. 24, 1996). In this
context, we draw no distinction between annuity contracts, retirement plans,
and life insurance policies. See Mathews v. Harris, 713 S.W.2d 311, 313
(Tenn. 1986) (applying Bowers to the designated beneficiary of retirement
benefits); Mathews v. Lawrence, 703 S.W.2d at 158 ("In the view of this
Court, the status of [a] designated beneficiary of refund of contributions [to
a retirement plan] is not materially different from the position of a designated
beneficiary of an insurance policy."); Teachers Ins. & Annuity Ass'n, 709
S.W.2d 592, 595 (Tenn. Ct. App. 1985) ("Although the appellant in this case
argues that there is a distinction between annuity agreements and a life
insurance policy, we are unable to see any distinction.").
 The chancery court determined that, when the plan administrator
finally received a copy of the MDA after Mr. Leary's death, his beneficiary
designation was revoked, consistent with the requirements of the MetroMax
Plan. The chancery court focused on the following provision:

 RETIREMENT/PENSION ACCOUNTS: The parties agree
 that the Husband shall be awarded all right, title and interest in
 the following retirement/pension accounts:
 a. All retirement that he may have through his employment
 with the Metro Government[.]
 - 25 -
 The MDA is a contract. Barnes v. Barnes, 193 S.W.3d 495, 498 (Tenn.
 2006). Because contract interpretation is a question of law, our review is de
 novo with no presumption of correctness. Id. We seek to ascertain and
 effectuate the parties' intent as expressed in the MDA, giving each word its
 natural and ordinary meaning. Long v. McAllister-Long, 221 S.W.3d 1, 9
 (Tenn. Ct. App. 2006).
 The retirement provision in the MDA did not revoke the beneficiary
 designation in the MetroMax Plan. Mr. Leary's retirement funds were
 marital property and thus subject to division in the MDA. Cohen v. Cohen,
 937 S.W.2d 823, 828-29 (Tenn. 1996); Mathews v. Lawrence, 703 S.W.2d at
 157. This provision awarded Mr. Leary sole control of his retirement account
 and extinguished any marital right or interest Ms. Johnson had in the
 account. Ms. Johnson's right to receive death benefits, however, depended
 solely on her status as the designated beneficiary. See Bowers, 637 S.W.2d
 at 457-58. Although Mr. Leary had the ability to change his designated
 beneficiary at any time by sending a written request to the plan administrator,
 he did not do so.
 Even if the language in the MDA had been sufficient to revoke the
 beneficiary designation, Mr. Leary did not send the MDA to the plan
 administrator. We will not enforce "[a] mere unexecuted intention to
 change" a beneficiary designation. Sun Life Assurance Co. v. Hicks, 844
 S.W.2d 652, 654 (Tenn. Ct. App. 1992) (quoting Cronbach v. Aetna Life Ins.
 Co., 284 S.W. 72, 73 (Tenn. 1926)). Tennessee courts require substantial
 compliance with the plan's terms to give effect to a purported beneficiary
 change. Id. To sustain a finding of substantial compliance, "it must be
 determined from the record that [the plan participant] took all reasonable
 steps possible to meet the conditions imposed by the [plan]." Id. This record
 falls short of that standard. See In re Estate of Williams, 2003 WL 1961805,
 at *19 (affirming ruling in favor of the beneficiary although the beneficiary
 had agreed in an MDA to waive any claim to husband's annuities, when "no
 attempt was made to change the beneficiary in compliance with the annuity
 contract provisions").
 Under these facts, we conclude that Mr. Leary's beneficiary
 designation was never revoked as provided in the MetroMax Plan. Thus, we
 reverse the chancery court's denial of Ms. Johnson's motion for judgment on
 the pleadings and the entry of judgment in favor of the Estate and remand
 this case for further proceedings consistent with this opinion.

Id. at *2-4.

 As these cases demonstrate, Tennessee courts have consistently applied Bowers in
cases involving marital dissolution agreements and their impact on beneficiary
 - 26 -
 designations, drawing no distinction between retirement plans, annuity contracts, and life
insurance policies. See Voya, 2017 WL 4864817, at *3. In fact, Voya reiterated that "the
reasoning in Bowers applies equally to the beneficiary designation in a retirement plan."
2017 WL 4864817, at *3 n.1. However, the trial court's order in this case, granting
summary judgment in favor of Mr. Birdwell's estate, did not mention any of this caselaw,
or any other legal authority aside from Tennessee Rule of Civil Procedure 56. Again, Ms.
O'Dell argues that Bowers and its progeny are controlling. The estate relies on Lunsford,
Manning, and In re Estate of Ellis (which we have already deemed distinguishable). We
conclude that Ms. O'Dell has the better argument.

 In Lunsford, this Court distinguished Bowers based on "the specific language" of
the marital dissolution agreement in that case. 2005 WL 2572389, at *1. It provided that
the wife waived "any right, title and interest which [] she may have now, or in the future,
to any retirement payment," as if she had signed waiver forms releasing her aforementioned
interest. Id. (emphasis added). In addition, she had a continuing duty to execute documents
necessary to accomplish the purpose and intent of the agreement. Id. Thus, we said this
specific language "differentiate[d]" the facts of Lunsford from the other cited cases and
would have required her to execute a release of the retirement plan death benefit. Id. at *3.

 The marital dissolution agreement in this case contains no such language. It only
mentioned the retirement account itself. It provided that each party would "receive their
own" retirement accounts, and Mr. Birdwell's retirement account would be his "sole and
absolute property." As such, the case before us is more like Estate of Williams, where "the
Williams MDA expressly referred to the annuity contract by name and number" and
awarded it to the husband "free of any claim by Wife." 2003 WL 1961805, at *18-19.
Even though the estate "attempted to distinguish Bowers on the grounds that the divorce
decree in Bowers did not expressly address the life insurance policy at issue," we found
there was "nothing about the language in the MDA to make inapplicable the principles" in
Bowers and subsequent cases. Id. Although Bowers involved "general language" and the
wife in Estate of Williams "agreed to waive any claim to the annuities themselves, the fact
remain[ed] that no attempt was made to change the beneficiary[.]" Id. at *19. Because the
MDA clearly awarded the annuities themselves to the husband, "he was free to name any
beneficiary he chose," including his ex-wife, whether they were married or not. Id.
Likewise, in Voya, the marital dissolution agreement specifically awarded the husband all
right, title and interest in "all retirement that he may have through his employment with the
Metro Government." 2017 WL 4864817, at *1. We held that "[t]his provision awarded
[him] sole control of his retirement account and extinguished any marital right or interest
[the wife] had in the account," but "[t]he retirement provision in the MDA did not revoke
the beneficiary designation in the [retirement] Plan." Id. at *4. The same reasoning applies
here.

 We acknowledge that Manning also involved a marital dissolution agreement in
which each party agreed "to waive any interest he/she may have in the other party's
 - 27 -
 retirement." 2016 WL 3640317, at *1. The Manning Court held that "[t]he facts presented
in Bowers are simply inapposite to the facts presented in this case" and determined that
"this case is more closely aligned with the facts presented in Lunsford and to an extent,
Ellis." Id. at *4. We do not reach the same conclusion here. We deem the long line of
cases from Bowers to Voya controlling.

 The Estate also argues on appeal that this marital dissolution agreement "placed a
continuing contractual obligation on [Ms.] O'Dell that would bind her to waive any current
or future right she may have in the retirement account[.]" However, this is the same
argument we rejected in Shell, 2006 WL 3193659, at *4. In that case, the decedent's estate
similarly argued that the facts "should be distinguished from Bowers and its progeny
because the parties' MDA contain[ed] a ‘continuing' obligation of ‘future' conduct, and
thus the wife's contractual obligation to refrain from making a claim should be enforced
such that she could not accept a refund of contributions made by the husband." Id.
Considering the language of the various agreements addressed in the cases, however, we
deemed this "a distinction without a difference." Id. In Bowers, the parties had agreed to
relinquish "to the other any rights or claims not provided for herein." Id. (quoting Bowers,
637 S.W.2d at 456). In TIAA v. Harris, the agreement was "much more comprehensive,"
and stated that each party waived and relinquished "all rights or claims which he or she
may have or hereafter acquire under the law of any jurisdiction to the other's property,"
and it went on to state that it applied to property currently owned or later acquired. Id.
(quoting TIAA v. Harris, 709 S.W.2d at 592). Thus, we explained that the TIAA v. Harris
agreement explicitly contemplated "current and future claims to current and future
property." Id. In other words, the Shell Court explained, the TIAA v. Harris agreement
stated "the same obligation that is in the MDA before us in a different way, i.e. the
obligation to refrain from making future claims to the other's property." Id. Still, Bowers
controlled. Id. As we noted above, the TIAA v. Harris provision, which was discussed at
length in Shell, is nearly identical to the one in this case.

 One final point deserves mention. As the United States Supreme Court observed in
2018,

 [C]limbing divorce rates led almost all States by the 1980s to adopt [a
 certain] kind of automatic-revocation law. So-called revocation-on-divorce
 statutes treat an individual's divorce as voiding a testamentary bequest to a
 former spouse. Like the old common-law rule, those laws rest on a
 "judgment about the typical testator's probable intent." [Sitkoff &
 Dukeminier, Wills, Trusts, and Estates] at 239. They presume, in other
 words, that the average Joe does not want his ex inheriting what he leaves
 behind.
 Over time, many States extended their revocation-on-divorce statutes
 from wills to "will substitutes," such as revocable trusts, pension accounts,
 and life insurance policies. See Langbein, The Nonprobate Revolution and
 - 28 -
 the Future of the Law of Succession, 97 Harv. L. Rev. 1108, 1109 (1984)
 (describing nonprobate assets). In doing so, States followed the lead of the
 Uniform Probate Code, a model statute amended in 1990 to include a
 provision revoking on divorce not just testamentary bequests but also
 beneficiary designations to a former spouse. See §§ 2-804(a)(1), (b)(1), 8
 U.L.A. 330, 330-331 (2013). The new section, the drafters wrote, aimed to
 "unify the law of probate and nonprobate transfers." § 2-804, Comment, id.,
 at 333. The underlying idea was that the typical decedent would no more
 want his former spouse to benefit from his pension plan or life insurance than
 to inherit under his will. A wealth transfer was a wealth transfer—and a
 former spouse (as compared with, say, a current spouse or child) was not
 likely to be its desired recipient. So a decedent's failure to change his
 beneficiary probably resulted from "inattention," not "intention." Statement
 of the Joint Editorial Bd. for Uniform Probate Code, 17 Am. College Trust
 & Est. Counsel 184 (1991). Agreeing with that assumption, 26 States have
 by now adopted revocation-on-divorce laws substantially similar to the
 Code's.

Sveen v. Melin, 584 U.S. 811, 814-15 (2018). Tennessee was not among those 26 states.
Id. at 815 n.1.

 Although this expanded form of the revocation-upon-divorce doctrine
 has been in existence for a number of years now, Tennessee has been slow
 to join the movement toward expanding the revocation-upon-divorce
 doctrine and instead retains the doctrine largely in its original form. . . .
 [U]nlike the UPC, Tennessee law fails to extend the revocation-upon-divorce
 doctrine to will substitutes such as life insurance policies, retirement plans,
 or annuities, though it does apply the doctrine to trusts.

Hailey H. David, The Revocation-Upon-Divorce Doctrine: Tennessee's Need to Adopt the
Broader Uniform Probate Code Approach, 39 U. Mem. L. Rev. 383, 385 (2009). "The
Tennessee opinions surrounding the treatment of life insurance, retirement accounts,
annuities, and trusts consistently use the same analysis and reasoning implied in one
seminal case, Bowers v. Bowers, in which the Tennessee Supreme Court held that the
revocation-upon-divorce doctrine did not apply to insurance policies." Id. at 400-01.

 Our decision in this case is consistent with the body of Tennessee law currently
governing the issue before us. Ms. O'Dell did not breach the parties' marital dissolution
agreement by receiving the proceeds of the retirement funds upon the death of Mr.
Birdwell. Thus, the trial court erred in granting summary judgment in favor of the Estate
on the breach of contact claim. We reverse and remand for entry of summary judgment in

 - 29 -
 favor of Ms. O'Dell.11

 V. CONCLUSION

 For the aforementioned reasons, the decision of the chancery court is hereby
reversed and remanded. Costs of this appeal are taxed to the appellee, the Estate of Michael
Birdwell, for which execution may issue if necessary.

 _________________________________
 CARMA DENNIS MCGEE, JUDGE

 11
 We note that this appeal only involves a breach of contract claim filed by the Estate against Ms.
O'Dell. The retirement plan administrator was not named as a defendant, and no issue of substantial
compliance was asserted by the Estate in the trial court or in its brief on appeal.
 - 30 -