METROPOLITAN LIFE INSURANCE COMPANY v. LAWLESS

CourtDistrict Court, D. New Jersey
DecidedNovember 15, 2019
Docket3:19-cv-13688
StatusUnknown

This text of METROPOLITAN LIFE INSURANCE COMPANY v. LAWLESS (METROPOLITAN LIFE INSURANCE COMPANY v. LAWLESS) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
METROPOLITAN LIFE INSURANCE COMPANY v. LAWLESS, (D.N.J. 2019).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY METROPOLITAN LIFE INSURANCE COMPANY, | Civil Action No, 19-13688(MAS)(ZNO) Plaintiff, : v. MEMORANDUM OPINION AND DENA LAWLESS, et al., | ORDER

Defendants.

This matter comes before the Court upon Defendants Cari Lawless and William Lawless’s Joint Motion to Stay the Proceedings Pending Resolution of the State Court Matters and/or to Decline Jurisdiction (“Motion to Stay’). (See Notice of Mot. to Stay, ECF No. 21.) Thomas Lawless and Cari Lawless’s two minor children (“the children”) join that Motion. (T.L. and R.L.’s Sept. 20, 2019, Letter (“TRL”) 1, ECF No. 27.) Dena Lawless opposes a stay of these proceedings, (Mem. in Opp’n to Mot. to Stay, ECF No. 30), and Metropolitan Life Insurance Company (“MetLife”) opposes a stay while it remains a party to the action, (MetLife’s Sept. 20, 2019, Letter (“MLL”) 1-2, ECF No. 29). . The parties’ initial briefing focused on the exceptional circumstances standard derived from Colorado River Water Conserv, Dist. v. United States, 424 U.S. 800, 817 (1976). In light of NYLife Distributors, Inc. v. Adherence Grp., Inc., 72 F.3d 371, 374 (3d Cir. 1995), in which the Third Circuit “h[e]ld the discretionary standard enunciated in Brillhart [v. Excess Insurance Company of America, 316 U.S. 491 (1942),] governs a district court’s decision to dismiss an action commenced under the interpleader statute during the pendency of parallel state court proceedings,” the Court requested the parties provide supplemental briefing on whether the Colorado River or

Brillhart standard applies. (Text Order, ECF No. 35.) Cari and William! submitted a joint supplemental brief advancing the Brillhart standard, (Supp. Br. in Support of Mot. 2, ECF No. 36), which the children joined, (T.L. and R.L.’s Nov. 4, 2019, Letter 1, ECF No. 38). And Dena submitted a supplemental brief contending the Colorado River standard is more appropriate, but also providing the Court with an analysis under the Brillhart standard. (Supp. Mem. in Opp’n to Stay 3-4, ECF No. 37.) For the reasons set forth below, the Court finds the Brillhart standard applies and that it is inappropriate, at this stage of the proceedings, to stay the case and deprive MetLife of access to expeditious interpleader relief as provided for by Congress when it enacted 28 U.S.C. § 1335. The Motion to Stay shall be denied without prejudice. I. ALLEGATIONS AND PROCEDURAL HISTORY Thomas Lawless (“the Decedent”) died on March 5, 2019, causing three life insurance plans to become payable to their identified beneficiaries. (MetLife’s Am. Compl. {{[ 30-31, ECF No. 4.) Each life insurance plan was maintained by one of the Decedent’s former employers, PricewaterhouseCoopers LLP (“PwC”), KPMG LLP, and Ernst & Young LLP (“E&Y”). (Id. Jf 9, 14, 22.) The KPMG and PwC plans are purportedly governed by the Employee Retirement Income Security Act (“ERISA”). (Ud. [ff 16, 24; Mem. in Support of Mot. to Stay 2, ECF No. 21-1.) On June 7, 2018, the designated beneficiary of each plan was changed to Dena, the Decedent’s wife. (MetLife’s Am. Compl. {J 2, 12, 20, 28.) Before that, the beneficiary of the PwC plan was William, the Decedent’s brother; the beneficiary of the KPMG plan was Cari, the Decedent’s ex-wife, and the children as contingent beneficiaries; and the beneficiaries of the E&Y plan were Cari (14%) and the two children (each 43%). Ud. Jl 3-6, 13, 21, 29.) MetLife is the administrator of each policy. (7d. {| 39-40.) Cari notified MetLife that she was declaring herself a rival beneficiary due

' The Court respectfully uses the parties’ first names to avoid confusion and to promote readability.

to a marital settlement agreement (“MSA”) she had with the Decedent that provided he would maintain two life insurance policies, one benefiting her and another benefiting the children. (/d. 34-36.) Cari filed a caveat, (Mem. in Support of Mot. to Stay 7), and on April 10, 2019, Dena filed a complaint in the Superior Court of New Jersey, Chancery Division, Probate Part, seeking to have herself declared an omitted spouse and seeking to be appointed administratrix of the Decedent’s estate (herein the “Probate Action”), (Mot. to Stay Ex. A 1, ECF No. 22). MetLife filed this interpleader action, naming Dena, Cari, William, and the children as defendants, in this Court on June 13, 2019, stating it was ready and willing to pay out the benefits under the three plans and asking the Court to allow it to deposit the funds into the Registry of the Court and to determine whom should receive the benefits under the plans. (Compl. {| 39-41, ECF No. 1; accord Am. Compl. { 39-41.) On August 14, 2019, the children filed an answer and counterclaim in the Probate Action through their guardian ad litem; through their counterclaim, the children challenge various transfers of the Decedent’s funds, including both the reassignment of benefits and certain inter vivos gifts, allegedly caused by Dena’s undue influence. (Mot. to Stay Ex. B 15, 16~17, ECF No. 21-4.) The same day, Cari moved in her divorce action against the Decedent before the New Jersey Superior Court, Chancery Division, Family Part, seeking to join the Decedent’s estate and Dena to (1) recover unreimbursed costs the Decedent owed for expenses incurred by the children, (2) discover all documents concerning the death benefit paid (or to be paid) to Dena under the KPMG plan, (3) recover her marital coverture fraction of the death benefits of the KPMG plan, (4) have the court find the Decedent violated the MSA, and (5) recover the life insurance benefit due under the MSA (herein the “Family Action”). (Mot. to Stay Ex. D 1-3, ECF No. 21-6.) On September 2, 2019, William filed a third-party complaint in the Probate Action challenging the Decedent’s

assignment of Dena as the beneficiary of the PwC plan. (Mot. to Stay Ex. C 1, 7-8, ECF No. 21- 5.) Cari and William now move “for an Order staying these proceedings pending resolution of the pending state court matters and/or to decline jurisdiction.” (Notice of Mot. to Stay.) The children join that motion. (TRL 1.) MetLife expressed no opinion about where the claims should be heard, but opposes the stay while it is still a party to the action. (MLL 1-2, ECF No. 29.) Dena opposes a stay. (Mem. in Opp’n to Mot. to Stay, ECF No. 30.) - IL PARTIES’ ARGUMENTS A. Cari and William’s Arguments in Support of a Stay Cari and William argue that, even accepting that the MSA is preempted by ERISA, Cari “ts still able to pursue her claim for a constructive trust in the Family Part action upon joinder of Dena,” and the children “are permitted to assert their claims of undue influence and lack of capacity irrespective of the federal preemption defense.” (Mem. in Support of Mot. to Stay 13.) Cari and William assert that the preemption claim is a “red herring.” (/d. at 20.) They contend that Dena “will seek to assert the preemption argument to dismiss.any claim of right that Cari [] asserts

.... At that point, the Court will be left with state law claims of constructive trust, estoppel, undue influence and lack of capacity.” (/d. at 21.) Cari and William submit that “[d]eclining jurisdiction ... would best serve the state courts’ interests in comity and would be consistent with long- standing practice of judicial restraint by federal courts as to matters of state law.” (d. (citing Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
METROPOLITAN LIFE INSURANCE COMPANY v. LAWLESS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/metropolitan-life-insurance-company-v-lawless-njd-2019.