Lincoln Life Assurance Company of Boston v. Meade

District Court, N.D. Indiana·Decided March 20, 2023·No. 4:22-cv-00027·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA HAMMOND DIVISION AT LAFAYETTE LINCOLN LIFE ASSURANCE COMPANY ) OF BOSTON f/k/a LIBERTY LIFE ) ASSURANCE COMPANY OF BOSTON and ) PROTECTIVE LIFE INSURANCE ) COMPANY, ) ) Plaintiffs, ) ) vs. ) CAUSE NO. 4:22-CV-27-PPS-JEM ) MARQUITTA MEADE, et al., ) ) Defendants. ) OPINION AND ORDER This unfortunate case is centered around siblings who dispute the disbursement of proceeds from their mother’s life insurance policy. Interpleader Plaintiffs, Lincoln Life, are in the center of the dispute holding the funds and they just want out of the case. As such, it has filed an amended motion for interpleader [DE 38] asking the Court to allow them to deposit the insurance proceeds at issue into the Court’s registry and discharge them from any further liability relating to the insurance policy. Because I find all of the requirements of interpleader have been met, I will grant the Interpleader Plaintiffs’ motion. Background On June 13, 2005, Liberty Life1 issued a life insurance policy to Martha M. Meade (the mother) in this case in the amount of $139,980.00. [Compl., DE 2, ¶ 12; Policy No.

75561245NU3.] According to the complaint “[i]n the application that was incorporated as part of the Policy, Marquitta Meade, Lance Meade, and Lesley Meade [three out of her five children] were designated as the Policy’s beneficiaries.” [Id. ¶ 12.] Plus, the annual reports that were sent to Mrs. Meade for years (2006-2017 to be exact), indicate that the Policy’s designated beneficiaries were Marquitta Meade, Lance Meade, and

Lesley Meade. [DE 38-1 at 2-24.] On November 3, 2017, Mrs. Meade changed the policy beneficiary to her Estate. [Compl. ¶ 13.] The heirs of the estate are the five children (in equal shares). One of the siblings, Marquitta Meade, has a theory about all of this. She believes the original insurance policy had all five siblings as the beneficiaries (and claims she spoke to an insurance representative on the phone who assured her this was correct, but

only three names could fit in the beneficiary designation form mailed out for years), and that her brother, Lesley (who is also an attorney), basically ushered their mother back to his house in Indiana after the mother had a stroke, and forced her to sign a change of beneficiary on the life insurance account, making her change the beneficiary to the Estate. [DE 43 at 1-4.]

1 More fully: Lincoln Life Assurance Company of Boston f/k/a Liberty Life Assurance Company of Boston and Protective Life Insurance Company. 2 Getting back to the hard facts of this case, as of September 1, 2019, Liberty Life Assurance Company of Boston changed its name to Lincoln Life Assurance Company of Boston, and the Policy was assigned a new policy number (No. CP6077156.) [Compl. ¶

14.] Also effective September 1, 2019, Protective became the administrator of the Policy. [Id. ¶ 15.] A few years after the change of beneficiary, Mrs. Meade died on October 27, 2020. [Id. ¶ 16.] A couple months later, Lincoln Life received an e-mail from defendant, Marquitta Meade, advising: “I am hereby submitting a claim that an error exists in my

mother’s life insurance policy and I am requesting that the benefit NOT be paid to her estate . . . My mother wanted the death benefit to go directly to each of the five siblings and never go through the Estate.” [Id. ¶ 17 (emphasis in original).] Marquitta Meade then sent them another e-mail about a month later advising “I want to challenge [payment of the proceeds to the Estate], legally, before any check is written.” [Id. ¶ 19.] However, the other siblings disagreed with Marquitta’s position. For example,

Laurence Meade and Millicent Meade stated in their answers that they “request[] that the proceeds of the life insurance policy that is the subject of this litigation be paid to the Estate of Martha M. Meade, which is the proper beneficiary of said policy proceeds being the last beneficiary designated by my mother.” [DE 50 at 1; DE 51 at 1.] Lesley Meade, who is an attorney himself and the executor of the Estate, also requested that

the life insurance proceeds be deposited into the registry of the Court. [DE 28 at 5.]

3 Lincoln Life sent correspondence to all five siblings telling them about the challenge to the Policy beneficiary designation, and providing them a 30-day courtesy period within which to explore resolution of their dispute. [Compl. ¶ 20.] They also

told the siblings if they couldn’t reach an agreement, they would refer the matter to their legal department for a potential interpleader. Id. As a result, Lincoln Life filed this lawsuit on April 14, 2022, against the five siblings and the Estate of Martha Meade. [Id. ¶ 22.] To date, no interpleader defendant has asserted a counterclaim against Lincoln Life.

On August 25, 2022, Lincoln Life filed what shows up on the docket as a motion to amend their motion for interpleader, but it is really an amended motion for interpleader of proceeds, and discharge and dismissal with prejudice. [DE 38.] The Estate of Martha Meade filed a response to the motion for interpleader, stating it had no objection to the discharge and dismissal of Lincoln Life upon payment of the proceeds into the Court, and is unaware of any malfeasance by Lincoln Life stating that the

annual reports of the Policy appear to be in order. [DE 63 at 2.] The parties have discussed a potential resolution to this case at length, trying to decide amongst themselves if the proceeds should go directly to all five siblings in equal portions, or go through the Estate (which, again, the heirs are the five siblings). In other words, everyone seems to agree that the proceeds should be divided equally

among the siblings, but the only question is whether the money should go directly to them or be funneled through the Estate first. 4 Extensive settlement discussions followed Lincoln Life’s amended motion, and, as a result, I put on hold ruling on the motion. [DE 53, 60, 78, 80, 83.] Unfortunately, the siblings have been unable to arrive at an agreement to resolve the matter.

Consequently, on March 13, 2023, Judge Martin had a telephonic conference with the parties and was advised that the offers and counteroffers to settle were rejected, and the parties now request rulings on all pending motions. [DE 82.] Therefore, it is proper to rule on the motion for interpleader. Discussion

It is common for insurance companies, like the Interpleader Plaintiffs in this case, to file an interpleader action for protection against problems posed by multiple claimants to a single fund. See Commercial Union Ins. Co. of New York v. Adams, 231 F.Supp. 860, 867 (S.D. Ind. 1964). Interpleader enables “a neutral stakeholder, usually an insurance company or a bank, to shield itself from liability for paying over the stake to the wrong party. This is done by forcing all the claimants to litigate their claims in a

single action brought by the stakeholder.” Indianapolis Colts v. Mayor and City Council of Baltimore, 733 F.2d 484, 486 (7th Cir. 1984). This equitable remedy of interpleader is codified in both statutory and rule form. See 28 U.S.C. § 1335; Fed. R. Civ. P. 22. The main distinction between these two are the jurisdictional prerequisites. Statutory interpleader under section 1335 requires only

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