Texas Exemptions and Life Insurance

New case out of the Fifth Circuit states that whole life insurance policy proceeds, if the policy is surrendered for cash prior to death, are not exempt under Texas law. See case here. Basically, exemption for insurance proceeds are only for the beneficiary. In this case, the owner of the policy is not the "beneficiary" of the policy, he is the "owner" of the policy, and the cash in is paid to him not as "insured", which would be exempt, or as "beneficiary", which would also be exempt, but as "owner".