Estate of John W. Alleman, Jr. v. Brooks

CourtDistrict Court, M.D. Pennsylvania
DecidedJune 25, 2020
Docket1:19-cv-00450
StatusUnknown

This text of Estate of John W. Alleman, Jr. v. Brooks (Estate of John W. Alleman, Jr. v. Brooks) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of John W. Alleman, Jr. v. Brooks, (M.D. Pa. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA PRINCIPAL LIFE INSURANCE : Civil No. 1:19-CV-00450 COMPANY, : : Plaintiff, : : v. : : BETTY JANE BROOKS and ESTATE : OF JOHN W. ALLEMAN, JR., : : Defendants. : Judge Jennifer P. Wilson MEMORANDUM This is an interpleader action brought under Federal Rule of Civil Procedure 22 by Plaintiff Principal Life Insurance Company (“Principal”) to determine the proper beneficiary for a $32,000 life insurance policy (“the policy”) that was owned by John W. Alleman, Jr. (“Alleman”), who is now deceased. The Defendants to the action are Alleman’s estate (“the estate”) and Betty Jane Brooks (“Brooks”). The estate has answered the complaint, but Brooks has not yet responded. The case is presently before the court on a motion for default judgment filed by Principal. For the reasons that follow, the motion for default judgment is granted in part and denied as moot in part. FACTUAL BACKGROUND AND PROCEDURAL HISTORY Principal filed the interpleader complaint that initiated this case on March 13, 2019. (Doc. 1.) According to the allegations in the complaint, Alleman was the holder of a life insurance policy through a group policy held by his employer, Associated Products Services, Inc. (Id. ¶ 6.) The policy was administered by Principal and subject to the terms of the Employee Retirement Income Security

Act of 1974 (“ERISA”). (Id. ¶¶ 4, 6). Alleman initially named Debra K. Alleman as the beneficiary of the policy, but subsequently changed the beneficiary to Brooks on April 1, 2010. (Id. ¶¶ 7–8.)

On May 1, 2015, Alleman died as a result of a gunshot wound to the head. (Id. ¶ 10.) Alleman’s death triggered Principal’s obligation to pay the $32,000 benefit owed under the policy. (Id. ¶ 11.) Brooks filed a claim for the benefit on May 11, 2015. (Id. ¶ 12.) After Brooks’s claim was filed, however, Principal

learned that local police were investigating Brooks for possible involvement in Alleman’s death and that the District Attorney planned to bring charges against Brooks. (Id. ¶ 13.) Because Pennsylvania’s slayer statute precludes the recovery

of a life insurance benefit by an individual who is convicted of killing the decedent, Principal did not pay the benefit to Brooks and instead filed the instant interpleader action seeking a court order as to the proper beneficiary of the benefits under the policy. (Id. ¶¶ 14–24.) The complaint names as defendants the estate

and Brooks. (Id. ¶¶ 2–3.) After Brooks failed to answer or otherwise respond to Principal’s interpleader complaint, the Clerk of Court entered default against Brooks on

August 12, 2019. (Doc. 14.) The estate answered the complaint on November 12, 2019. (Doc. 18.) The case was then reassigned from United States District Judge Yvette Kane to the undersigned pursuant to a verbal order from then-Chief United

States District Judge Christopher C. Conner on November 19, 2019. Principal filed the instant motion for default judgment and a supporting brief on November 20, 2019, seeking (1) default judgment against Brooks, (2) an award

of attorney’s fees and costs in the amount of $6,880.31, (3) a court order requiring the proceeds of the policy to either be disbursed to the estate or deposited into the court’s registry, and (4) a court order discharging Principal of all liability under the policy. (Docs. 19–20.) Neither defendant filed a brief opposing the motion,

making it ripe for the court’s review. JURISDICTION Federal law provides two means for a plaintiff to bring a claim for equitable

interpleader: statutory interpleader under 28 U.S.C. § 1335 and rule interpleader under Federal Rule of Civil Procedure 22. Metro. Life Ins. Co. v. Price, 501 F.3d 271, 275 (3d Cir. 2007). Where, as here, a claim is brought under Rule 22, a plaintiff “must plead and prove an independent basis for subject matter

jurisdiction,” because Rule 22 is “no more than a procedural device.” Id. (citing NYLife Distribs., Inc. v. Adherence Grp., Inc., 72 F.3d 371, 372 n.1 (3d Cir. 1995)). Principal alleges that this court has federal question jurisdiction because the policy at issue is a life insurance policy under ERISA. (Doc. 1 at 1–2.) The Third

Circuit has held that a federal court has subject matter jurisdiction over a rule interpleader action where the complaint seeks a ruling regarding the proper beneficiary of an ERISA life insurance policy. Price, 501 F.3d at 276–77.

Principal’s allegation that the policy was issued under ERISA is therefore sufficient to confer subject matter jurisdiction on this court. Id. DISCUSSION A claim for equitable interpleader allows an entity holding property “to join

in a single suit two or more persons asserting claims to that property.” Price, 501 F.3d at 275. “The plaintiff in an interpleader action is a stakeholder that admits it is liable to one of the claimants, but fears the prospect of multiple liability.” Id.

“Interpleader allows the stakeholder to file suit, deposit the property with the court, and withdraw from the proceedings. The competing claimants are left to litigate between themselves.” Id. Interpleader actions typically proceed in two steps. Prudential Ins. Co. of

Am. v. Hovis, 553 F.3d 258, 262 (3d Cir. 2009). “During the first stage, the court determines whether the interpleader complaint was properly brought and whether to discharge the stakeholder from further liability to the claimants.” Id. (citing

NYLife, 72 F.3d at 375). “During the second stage, the court determines the respective rights of the claimants to the interpleaded funds.” Id. (citing NYLife, 72 F.3d at 375).

An interpleader action is properly brought where the named beneficiary of a life insurance policy is potentially barred from recovering under the policy because of her alleged role in the killing of the decedent. Prudential Life Ins. Co. of Am. v.

White, No. 1:16-CV-01094, 2017 WL 2834459, at *3 (M.D. Pa. June 29, 2017). In such a situation, “[a]n insurer faced with potentially conflicting claims by a possible slayer and the insured’s estate may absolve itself of excess liability by paying the proceeds into the registry of the court and filing an action in

interpleader to determine the proper recipient.” Id. (quoting Overstreet v. Ky. Cent. Life Ins. Co., 950 F.2d 931, 940 (4th Cir. 1991)). Accordingly, Principal’s interpleader action is properly brought here because Principal seeks to resolve

“potentially conflicting claims by a possible slayer and the insured’s estate.” Id. The court therefore turns its attention to Principal’s motion for default judgment. As noted above, the motion seeks (1) default judgment against Brooks, (2) an award of attorney’s fees and costs in the amount of $6,880.31, (3) a court

order requiring the proceeds of the policy to either be disbursed to the estate or deposited into the court’s registry, and (4) a court order discharging Principal of all liability under the policy. At the outset, the court will grant Principal’s motion to the extent that it seeks interpleader relief discharging Principal of all liability under the policy.

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