Naftali Kunstlinger v. Lincoln Benefit Life Co

CourtCourt of Appeals for the Third Circuit
DecidedNovember 14, 2025
Docket25-1264
StatusUnpublished

This text of Naftali Kunstlinger v. Lincoln Benefit Life Co (Naftali Kunstlinger v. Lincoln Benefit Life Co) 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
Naftali Kunstlinger v. Lincoln Benefit Life Co, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ______________

No. 25-1264

NAFTALI KUNSTLINGER as Trustee of THE PINCHAS STOLPER INS TRUST 3/06/08, Appellant

v.

LINCOLN BENEFIT LIFE COMPANY _____________

On Appeal from the United States District Court for the District of New Jersey (D.C. No. 1:22-cv-04534) U.S. District Judge: Honorable Edward S. Kiel ______________

Submitted Under Third Circuit L.A.R. 34.1(a) November 10, 2025 ______________

Before: SHWARTZ, MATEY, and MONTGOMERY-REEVES, Circuit Judges.

(Filed: November 14, 2025)

______________

OPINION *

∗ This disposition is not an opinion of the full court and pursuant to I.O.P. 5.7 does not constitute binding precedent. SHWARTZ, Circuit Judge.

Naftali Kunstlinger, as Trustee of the Pinchas Stolper Ins Trust 3/06/08 (the

“Trust”), appeals the District Court’s order granting Lincoln Benefit Life Company

(“Lincoln”) summary judgment on Kunstlinger’s breach of contract and estoppel claims.

For the following reasons, we will affirm.

I

A

In 2008, Lincoln issued a $7.5 million life insurance policy to the Trust that

insured the life of Phineas “Pinchas” Stolper. According to the Policy, if the Trust failed

to make the required payments, Lincoln would provide a sixty-one day grace period

before coverage lapsed, and notify the Trust of the nonpayment “at least [thirty] days

prior to the day coverage lapses.” App. 64.

From April 2011 through May 2021, Kunstlinger made monthly payments of

either $19,995.50 or $19,996.50. In a December 2020 letter, Lincoln informed

Kunstlinger that the Policy had entered the 61-day grace period and would terminate

unless a $116,841.94 minimum payment was made on or before February 14, 2021.

Kunstlinger called Lincoln in February 2021, inquiring about this letter and the

minimum payment amount. A Lincoln representative told Kunstlinger that a “surrender

charge” 1 led Lincoln to issue the December 2020 grace period notice. App. 357.

Kunstlinger inquired whether he had to make the $116,841.94 payment listed in the letter.

1 A “surrender charge” is a set amount Lincoln will charge upon termination of the Policy. 2 The Lincoln representative replied, “[a]s of right now, your policy is not in a grace

[period],” because other payments had been received since the letter was sent, and that he

arranged for Kunstlinger to receive an “illustration so [he would] . . . know . . . the

minimum premium . . . need[ed] to . . . keep [the Policy] active so that this doesn’t

happen again.” App. 357. The Lincoln representative confirmed that the Policy was

active “as of now.” Id.

The next day, Lincoln sent Kunstlinger an illustration (a status report about the

Policy). The cover letter accompanying the illustration advised Kunstlinger that the

Policy “requires [an] immediate lump sum [payment] in the amount of $206,000 to carry

the policy through current year.” App. 360. In a March 15, 2021 letter, Lincoln

informed Kunstlinger that the Policy had entered a grace period and would terminate at

the end of a 61-day period unless a $150,657.27 minimum payment was made on or

before May 15, 2021. Kunstlinger ignored this letter and continued to make payments of

only $19,996.50. In a May 2021 letter, Lincoln informed Kunstlinger that “[t]he grace

period has expired and [the] policy has lapsed with no value and all benefits are forfeited

and void.” App. 427. Stolper died in May 2022, and Lincoln declined to pay the death

benefit.

B

Kunstlinger sued Lincoln, alleging that Lincoln breached the Policy by not paying

the death benefit and that Lincoln was equitably estopped from terminating the Policy.

Following discovery, both parties moved for summary judgment.

3 The District Court denied Kunstlinger’s motion for summary judgment and

granted Lincoln’s cross-motion for summary judgment, holding: (1) the March 2021

grace notice Lincoln provided Kunstlinger was valid under the Policy even though it did

not specify a minimum payment amount due, and (2) Lincoln was not equitably estopped

from terminating the Policy based on the February 2021 phone call because Lincoln did

not misrepresent what payments were required to keep the Policy in force, and, in any

event, Kunstlinger was not reasonably misled because the Policy and information he

received in February and March 2021 should have corrected any misconception about the

payments. Kunstlinger as Tr. of Pinchas Stolper Ins Tr. 3/06/08 v. Lincoln Benefit Life

Co., No. 22-cv-04534, 2025 WL 252432, at *5-10 (D.N.J. Jan. 21, 2025).

Kunstlinger appeals.

II 2

We first consider Kunstlinger’s claim that the grace notice was invalid. Under

New Jersey law, 3 “an insurance policy should be interpreted according to its plain and

ordinary meaning.” Voorhees v. Preferred Mut. Ins. Co., 607 A.2d 1255, 1260 (N.J.

2 The District Court had jurisdiction under 28 U.S.C. § 1332. We have jurisdiction under 28 U.S.C. § 1291. We exercise plenary review of the District Court’s order granting summary judgment. Resch v. Krapf’s Coaches, Inc., 785 F.3d 869, 871 n.3 (3d Cir. 2015). We apply the same standard as the District Court, viewing facts and drawing all reasonable inferences in the non-movant’s favor. Hugh v. Butler Cnty. Fam. YMCA, 418 F.3d 265, 266-67 (3d Cir. 2005). Summary judgment is appropriate where “there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a). 3 The parties agree New Jersey law applies. 4 1992). The plain and ordinary meaning of the Policy’s terms therefore governs the grace

notice’s requirements.

The notice here fulfills the Policy’s requirements. First, the Policy provides that

Lincoln “will send a written notice to the [policyholder’s] most recent address . . . at least

30 days prior to the day coverage lapses.” App. 64. Lincoln notified Kunstlinger in

writing on March 15, 2021, that the Policy had entered a grace period and would

terminate unless a $150,657.27 minimum payment was made by May 15, 2021—more

than 30 days from the letter’s date. Second, contrary to Kunstlinger’s assertion, neither

the Policy nor New Jersey law require grace notices to include the amount due to keep

the policy active. App. 64 (Policy stating only “[i]f you do not make sufficient payment

by the end of the grace period, the certificate will lapse”); N.J. Admin. Code § 11:4-

41.3(b)(2) (state law requiring only that policies include grace period). Without that

baseline obligation, the parties’ dispute over whether the amount requested in the grace

notice accurately described the minimum payment necessary to prevent lapse through

May 15, 2021, is immaterial. See Razak v. Uber Techs., Inc., 951 F.3d 137, 145 n.8 (3d

Cir. 2020) (“Summary judgment is correctly granted in many situations where the parties

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