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Minnesota Life Insurance Co. v. Lightfoot

United States District Court, W.D. Louisiana, Lafayette Division

February 5, 2018

MINNESOTA LIFE INSURANCE COMPANY
v.
REVA LIGHTFOOT, ET AL.

          UNASSIGNED DISTRICT JUDGE

          REPORT AND RECOMMENDATION

         PATRICK J. HANNA UNITED STATES MAGISTRATE JUDGE

         Currently pending before the court are three motions, plaintiff Minnesota Life Insurance Company's motion to dismiss (Rec. Doc. 24), defendant Deidra Darby's motion for summary judgment concerning the claim of defendant Reva Lightfoot (Rec. Doc. 26), and defendant Deidra Darby's motion for summary judgment concerning the claim of defendant Samantha Booker (Rec. Doc. 27). The motions were referred to the undersigned for review, report, and recommendation in accordance with the provisions of 28 U.S.C. § 636 and the standing orders of this Court and were submitted for resolution without oral argument. Considering the evidence, the law, and the arguments of the parties, and for the reasons fully explained below, it is recommended that ruling on the defendant's motion to dismiss be DEFERRED and that both motions for summary judgment be DENIED.

         Background

         Based on the record currently before the court, the following facts are undisputed. Henry L. Darby, Jr. was insured under Group Policy No. 0033894, which was issued by Minnesota Life Insurance Company to Cameron International Corporation. The group policy afforded basic life insurance in the amount of $84, 000 and supplemental life insurance in the amount of $209, 000. Mr. Darby designated his mother as his sole beneficiary, and he did not designate a secondary or contingent beneficiary. When Mr. Darby died on July 31, 2015, however, his mother had already predeceased him. Therefore, under the terms of the insurance policy, the proceeds were to be paid to Mr. Darby's surviving children in equal shares.

         Mr. Darby's obituary stated that he had five children: Reva Lightfoot, Anastasia Boyd, L.B., Dahlia Darby, and Quintus Williams. Mr. Williams did not assert a claim to the insurance proceeds, but claims were asserted by or on behalf of the other four persons identified in the obituary as Mr. Darby's children. Deidra Darby (Mr. Darby's ex-wife and the mother of his daughter Dahlia) disputed the validity of the claims asserted by Ms. Lightfoot, Ms. Boyd, and L.B., arguing in correspondence to the plaintiff that Ms. Lightfoot, Ms. Boyd, and L.B. actually were not Mr. Darby's children. Because none of the claimants disputed Ms. Darby's claim that Dahlia was Mr. Darby's daughter, Minnesota Life paid one-fifth of the policy proceeds to Ms. Darby for Dahlia's benefit.

         Jones Funeral Home, Inc. also asserted a claim to a portion of the insurance proceeds based on Ms. Darby, Ms. Boyd, Ms. Lightfoot, and Samantha Booker (L.B.'s mother) each having individually executed a document stating that she was assigning to Jones the sum of $14, 063.58 from the anticipated payment of insurance policy proceeds. This Court assumes that this was the amount that Jones charged for Mr. Darby's funeral.

         Minnesota Life initiated this interpleader proceeding pursuant to Rule 22 of the Federal Rules of Civil Procedure then filed a motion to dismiss, alleging that it claims no interest in the policy proceeds, is a mere stakeholder, is uncertain as to the proper beneficiaries of the policy proceeds, and is uncertain as to the validity of the assignments in favor of Jones. Minnesota Life deposited into the registry of the court the sum of $254, 011.47, representing the face value of the coverages afforded by the group life insurance policy ($84, 000 $209, 000 = $293, 000) minus the payment already made to Ms. Darby for Dahlia's benefit ($58, 600), plus accrued interest. Minnesota Life named Ms. Lightfoot, Ms. Boyd, Ms. Darby (on behalf of Dahlia), Ms. Booker (on behalf of L.B.), and Jones as defendants in the suit.

         Although she was served, Ms. Boyd has not answered Minnesota Life's complaint or appeared in this lawsuit in any capacity.

         The Parties' Contentions

         By means of its motion to dismiss (Rec. Doc. 24), Minnesota Life seeks (1) to have the claimants' right to the proceeds determined by the court; (2) to have the claimants barred from seeking recovery under the subject insurance policy from Minnesota Life other than as determined in this lawsuit; (3) to recover costs and fees in the amount of $19, 595.31; and (4) to be dismissed from this lawsuit with prejudice.

         In her first motion for summary judgment (Rec. Doc. 26), Ms. Darby seeks to have Ms. Lightfoot's claim to the insurance proceeds invalidated.

         In her second motion for summary judgment (Rec. Doc. 27), Ms. Darby seeks to have L.B.'s claim to the insurance proceeds invalidated.

         Law and Analysis

         A. The Standard for Analyzing an Interpleader Action

         The court “has broad powers in an interpleader action.”[1] Interpleader actions are generally divided into two stages. The court first determines whether the requirements for an interpleader action have been met, including deciding whether there is a single fund at issue and whether there are adverse claimants to that fund.[2]If the court decides that the requirements for interpleader are met, it then determines the respective rights of the claimants to the funds deposited with the court, with each claimant occupying an adversary position to the others.[3] Absent any special circumstances, the second stage will proceed like any other action; if there are no genuine issues of material fact that require proceeding to trial, the second stage may be adjudicated through summary-judgment motions.[4]

         B. Interpleader is ...


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