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Metropolitan Life Insurance Co. v. Jackson

United States District Court, M.D. Louisiana

December 4, 2018




         Before the Court are three Motions for Default Judgment filed by Plaintiff in Interpleader Metropolitan Life Insurance (“MetLife”) against Sebastian Hill (Doc. 61), Jonathan Hill (Doc. 62) and Alexis Hill (Doc. 63). Jurisdiction is proper under 28 U.S.C. § 1331. For the following reasons, the Motions for Default Judgement (Docs. 61, 62, and 63) are GRANTED.

         I. BACKGROUND

         MetLife, an insurance provider, provided a group life insurance plan (the “Plan”) to the City of Baton Rouge, Louisiana, in which John Jackson (the “Insured”) was a participant. (Doc. 1 at ¶ 7). Willie Lee Jackson Sr. (“Jackson”) is the Insured's son. The Insured's Plan stated that if no beneficiary for monies payable at the Insured's death was designated, MetLife may decide that certain surviving family members are to be designated to be the beneficiaries of the life insurance payment. (Id. at ¶ 8). MetLife claims that the Insured executed a form designating his wife, Anna M. Jackson (“Ms. Jackson”) as beneficiary under the Plan. (Doc. 1 at ¶ 9). Plaintiff further alleges that on March 16, 2017, a power of attorney previously executed on behalf of the Insured by Alexis Hill, Ms. Jackson's nephew, was used to sign a Beneficiary Designation Form, removing Ms. Jackson and designating Alexis Hill as primary beneficiary, and Alexis Hill's sons Jonathan Hill and Sebastian Hill as contingent beneficiaries.[1] (Id. at ¶ 13). This new Beneficiary Designation Form stated that the Insured revoked any previous designations of primary and contingent beneficiaries. MetLife avers that Ms. Jackson died on August 10, 2015, predeceasing the Insured. (Id. at ¶ 15). The Insured died on November 20, 2015. (Id. at ¶ 16). Upon the Insured's death, MetLife wrote to Jackson requesting him to submit a claimant's affidavit for the value of the death benefits. (Id. at ¶ 18). Jackson returned the claim form on January 8, 2016. (Id. at ¶ 19). On December 21, 2015, MetLife wrote to Alexis Hill to inform him that the power of attorney that he used to change the Beneficiary Designation Form did not give him the authority to do so. (Id. at ¶ 20). On March 1, 2016 MetLife wrote to counsel for Jackson, Alexis Hill, Sebastian Hill, and Jonathan Hill indicating that their claims were adverse to each other, and that MetLife, by law, was required to file an interpleader action. However, MetLife urged the parties to amicably settle the matter before the interpleader action was filed. (Id. at ¶ 24). The interpleader action was filed on March 6, 2017. (Doc. 5). The Court entered an injunction on April 5, 2017 enjoining Defendants from instituting any other suit against MetLife relating to the death benefits of the Insured, pursuant to 28 U.S.C. § 2361 (Doc. 5 at p. 1).

         Plaintiff avers that despite numerous attempts to serve Non-Responsive Defendants, it has been unable to do so. (Doc. 61 at p. 1). Plaintiff asserts that it attempted service via publication in the Chicago Tribune and the (Baton Rouge) Advocate, pursuant to 28 U.S.C. 1655, to no avail. (Id.) Plaintiff's notices stated “If you fail to appear or plead by April 19, 2018, the court will proceed as if you have been served with process.” (Id.). As of this date, Non-Responsive Defendants have not participated in any aspect of this matter. The Clerk of Court entered default against Non-Responsive Defendants on June 4, 2018. (Doc. 56). MetLife then filed the pending Motions for Default Judgment. (Docs. 61, 62, and 63).


         The United States Court of Appeals for the Fifth Circuit has adopted a three step process to obtain a default judgment. See New York Life Ins. Co. v. Brown, 84 F.3d 137, 141 (5th Cir. 1996). First, a default occurs when a party “has failed to plead or otherwise defend” against an action. Fed.R.Civ.P. 55(a). Next, an entry of default must be entered by the clerk when the default is shown “by affidavit or otherwise.” See id.; NewYork Life, 84 F.3d at 141. Third, a party may apply to the court for a default judgment after an entry of default. Fed.R.Civ.P. 55(b); New York Life, 84 F.3d at 141.

         After a party files for a default judgment, courts must apply a two-part process to determine whether a default judgment should be entered. First, a court must consider whether the entry of default judgment is appropriate under the circumstances. Lindsey v. Prive Corp., 161 F.3d 886, 893 (5th Cir. 1998). Several factors are relevant to this inquiry, including: (1) whether there are material issues of fact at issue, (2) whether there has been substantial prejudice, (3) whether the grounds for default have been clearly established, (4) whether the default was caused by excusable neglect or good faith mistake, (5) the harshness of the default judgment, and (6) whether the court would think itself obliged to set aside the default on a motion by Defendant. Id.

         Second, the court must assess the merits of the plaintiff's claims and determine whether the plaintiff has a claim for relief. Nishimatsu Constr. Co. v. Houston Nat'l Bank, 515 F.2d 1200, 1206 (5th Cir. 1975); Hamdan v. Tiger Bros. Food Mart, Inc., No. CV 15-00412, 2016 WL 1192679, at *2 (M.D. La. Mar. 22, 2016).


         A. Default Judgment is Appropriate under the Lindsey Factors

          The Court must first decide whether the entry of default judgment is appropriate under the circumstances, by considering the Lindsey factors. First, there are no material facts in dispute because Non-Responsive Defendants failed to file an Answer or motion under Rule 12. Second, it is undisputed that Non-Responsive Defendants have not responded to any of MetLife's attempts to contact them. Third, the grounds for granting a default judgment against Non-Responsive Defendants are clearly established, as evidenced by the action's procedural history and the Clerk's entry of default. Fourth, the Court has no basis to find that Non-Responsive Defendants' failure to respond was the result of a good faith mistake or excusable neglect because they have failed to respond to MetLife or to the Court. Fifth, Non-Responsive Defendants' failure to file any responsive pleading or motion mitigates the harshness of a default judgment. Finally, the Court is not aware of any facts that would lead it to set aside the default judgment if challenged by Non-Responsive Defendants. The Court therefore finds that the six Lindsey factors weigh in favor of entry of default against Non-Responsive Defendants.

         B. The Sufficiency of the Pleadings

         The Court must also determine whether MetLife's pleadings provide a sufficient basis for a default judgement. MetLife filed the interpleader complaint against ...

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