Andrew Schlafly v. Eagle Forum

CourtCourt of Appeals for the Third Circuit
DecidedApril 28, 2022
Docket19-2405
StatusUnpublished

This text of Andrew Schlafly v. Eagle Forum (Andrew Schlafly v. Eagle Forum) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Andrew Schlafly v. Eagle Forum, (3d Cir. 2022).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

_______________________

Nos. 19-2405, 19-2406, 19-2583 _______________________

ANDREW L. SCHLAFLY, on behalf of himself individually and on behalf of all other members of Eagle Forum, a non-profit membership corporation, Appellant in No. 19-2405

v.

EAGLE FORUM; EDWARD R. MARTIN, JR., MO; JOHN F. SCHLAFLY; ESTATE OF PHYLLIS M. SCHLAFLY; EAGLE TRUST FUND; EAGLE FORUM EDUCATION & LEGAL DEFENSE FUND

EDWARD R. MARTIN, JR., MO; JOHN F. SCHLAFLY; ESTATE OF PHYLLIS M. SCHLAFLY; EAGLE TRUST FUND; EAGLE FORUM EDUCATION & LEGAL DEFENSE FUND, Appellants in Nos. 19-2406, 19-2583

On Appeal from the United States District Court for the District of New Jersey (District Court No. 2-17-cv-02522) District Judge: Honorable Esther Salas __________________________

Submitted Under Third Circuit L.A.R. 34.1 (a) March 3, 2022

Before: McKEE, AMBRO, and SMITH, Circuit Judges

(Filed: April 28, 2022) __________________________

OPINION* __________________________

SMITH, Circuit Judge

Andrew Schlafly and Eagle Trust Fund1 appeal various aspects of the District

Court’s judgment dismissing their claims. Because the District Court did not err, we will

affirm.

I.

This case involves the proceeds from two keyman insurance policies on the life of

the late Phyllis Schlafly. One of the policies was issued by Lincoln National Life Insurance

Company, which is incorporated in Indiana and headquartered in Pennsylvania. The other

was issued by John Hancock Life Insurance Company, which is headquartered and

incorporated in Massachusetts. The policies were not executed in New Jersey.

Both policies identify “Eagle Forum” as the beneficiary. The address given to

identify Eagle Forum, however, has never been used by it. In one of the policies, Phyllis

also identified Eagle Forum by its Employer Identification Number (“EIN”).

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. 1 For purposes of this opinion “Eagle Trust Fund” encompasses the “Eagle Trust Appellants”: Eagle Trust Fund, Eagle Forum Education and Legal Defense Fund, Edward R. Martin, Jr., Mo, John F. Schlafly, and the Estate of Phyllis Schlafly. 2 As a result of disputes arising during the course of the 2016 Republican presidential

primary, the Eagle Forum Board of Directors split into factions. Andrew Schlafly, the

decedent’s son, alleges that since that time, Eagle Forum has been without a functioning

Board. Litigation related to Eagle Forum’s Board is ongoing in Illinois, where Eagle

Forum is incorporated and has its principal place of business.

Andrew sued the insurance companies in the Superior Court of New Jersey seeking

the proceeds from the policies. In response, the insurance companies removed the case to

the District Court for the District of New Jersey, submitted the funds to that court, and

invoked statutory interpleader. Andrew then filed an amended complaint against Eagle

Forum and Eagle Trust. Counts I and VI—which the District Court called “Interpleader

Claims”—sought the funds from the life insurance policies by arguing that the members of

Eagle Forum, not Eagle Forum itself, were the intended beneficiaries of the policies.

Counts II through V—which the District Court labeled as “New Claims”—alleged various

misdeeds by Eagle Forum’s Board of Directors.2 Eagle Forum answered and asserted

claims against Andrew and Eagle Trust seeking a declaratory judgment as to whether they

were entitled to the life insurance proceeds and for attorneys’ fees.

2 Count II alleged that there was a civil conspiracy to dissipate funds from Eagle Forum. Count III asserted a claim for “conversion” as Andrew averred that Eagle Forum had “intentionally and wrongfully interfered with the rights of membership.” Count IV presented a “breach of contract” claim based on Eagle Forum allegedly violating its bylaws. And Count V, entitled “unjust enrichment,” sought damages, which “include[], but [are] not limited to the demand for proceeds on the policies.”

3 Eagle Trust also filed five crossclaims against Eagle Forum. Eagle Trust now

admits that it is not a beneficiary of the policies. It brought two breach-of-contract claims,

a claim for reimbursement of payments made on a separate life insurance policy,3 and two

claims for misappropriation of Eagle Trust’s intellectual property.

When considering the cross-motions to dismiss, the District Court held that the life

insurance contracts unambiguously identified Eagle Forum, not its members, as the

beneficiary. The Court then held that it lacked personal jurisdiction over Eagle Forum as

to Andrew’s New Claims. It also concluded that Eagle Trust’s crossclaims did not “arise

out of the same transaction or occurrence” as the Interpleader Claims, and, as such, it

dismissed Eagle Trust’s claims for lack of personal jurisdiction.4 The Court then ordered

the interpleaded funds to be disbursed to Eagle Forum.

II.5

The Court correctly determined that the policies unambiguously identify Eagle

Forum as the beneficiary. Andrew argues that Eagle Forum is not the proper beneficiary

3 This policy insured the life of Helen Marie Taylor. 4 The parties dispute whether the District Court dismissed Eagle Trust’s claims for lack of personal jurisdiction. We view the Court as dismissing Eagle Trust’s claims on this basis. Moreover, even if these claims were dismissed on other grounds “[w]e may affirm on any basis supported by the record, even if it departs from the District Court’s rationale.” TD Bank N.S. v. Hill, 928 F.3d 259, 270 (3d Cir. 2019). 5 The District Court had subject-matter jurisdiction pursuant to 28 U.S.C. §§ 1332 and 1335. We have jurisdiction pursuant to 28 U.S.C. § 1291. We exercise plenary review over a district court’s decision to dismiss for lack of personal jurisdiction and for failure to state a claim. Danziger & De Llano, LLP v. Morgan Verkamp LLC, 948 F.3d 124, 129 (3d 4 because its Board does not truly represent the members. But that is an internal dispute

between Eagle Forum’s members and its Board; it does not change the contracts’ plain

language. Although the street address used in the policies was not used by Eagle Forum,

the fact remains that the policies unambiguously identify “Eagle Forum”—not some

amorphous mass of its members—as their beneficiary. This conclusion is further

confirmed by the use of Eagle Forum’s EIN. Thus, the Court correctly decided that Eagle

Forum was entitled to the funds. See United States v. Pantelidis, 335 F.3d 226, 235 (3d

Cir. 2003) (holding that the determination of whether a contract is ambiguous is a matter

of law).

The Court also correctly held that it lacked personal jurisdiction over the New

Claims.6 Personal jurisdiction can be either specific or general. Ford Motor Co. v. Mont.

Eighth Jud. Dist. Ct., 141 S. Ct. 1017, 1024 (2021). The District Court lacked general

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Andrew Schlafly v. Eagle Forum, Counsel Stack Legal Research, https://law.counselstack.com/opinion/andrew-schlafly-v-eagle-forum-ca3-2022.