New York Life Insurance Company v. Del Valle

CourtDistrict Court, M.D. Pennsylvania
DecidedJune 29, 2020
Docket1:20-cv-00192
StatusUnknown

This text of New York Life Insurance Company v. Del Valle (New York Life Insurance Company v. Del Valle) 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
New York Life Insurance Company v. Del Valle, (M.D. Pa. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

NEW YORK LIFE INSURANCE CO., : Plaintiff : : No. 1:20-cv-00192 : v. : (Judge Kane) : ALIDA DEL VALLE, A.S., a minor, : by Gail Guida Souders, Esq., Guardian : Ad Litem, and R.S., a minor, by Gail : Guida Souders, Esq., Guardian Ad Litem, : Defendants :

MEMORANDUM

Before the Court in the above-captioned case is the parties’ Joint Motion for Interpleader Relief. (Doc. No. 9.) For the reasons that follow, the Court will grant the motion. I. BACKGROUND1 On February 4, 2020, Plaintiff New York Life Insurance Company (“Plaintiff”) filed an Interpleader Complaint to resolve potentially competing claims to a $500,000.00 Death Benefit (the “Death Benefit”) as a result of the death of Roberto Sotolongo Prieto (the “Insured”), who applied to Plaintiff for coverage under an individual life insurance policy (the “Life Insurance Application”) on or about September 2, 2018. (Doc. No. 1 ¶¶ 7-11.) On the Life Insurance Application, the Insured designated his spouse, Alida Del Valle, as the sole Class 1 beneficiary to the life insurance policy death benefits, and his children, A.S. and R.S., minors, as co-equal Class 2 beneficiaries. (Id. ¶ 8.) Accordingly, Defendants in this case are Alida Del Valle and A.S. and R.S., minors, by Gail Guida Souders, Esq., Guardian Ad Litem. The terms of the Life Insurance Application provided that the Insured received a Receipt

1 The following facts underlying Plaintiff’s claim are taken from Plaintiff’s Interpleader Complaint. (Doc. No. 1.) and Temporary Coverage Agreement (“TCA”), which, under specific conditions, provides a limited amount of temporary life insurance coverage during the pendency of the application review process. (Id. ¶ 9.) The Insured died on October 18, 2018, and his death was ruled a homicide. (Id. ¶ 10.) Because of the Insured’s death, the Death Benefit under the TCA became

due to a beneficiary or beneficiaries. (Id. ¶ 11.) Plaintiff concedes liability for a Death Benefit in the amount of $500,000.00. (Id.) Defendant Del Valle asserted a claim to the Death Benefit by submission of a Death Benefits Proceeds Form dated November 11, 2018. (Id. ¶ 12.) Plaintiff alleges that law enforcement officials investigating the Insured’s death have not ruled Defendant Del Valle out as a suspect in connection with the Insured’s death. (Id. ¶ 13.) At issue in this action is a determination as to which party or parties are entitled to the Death Benefit. Despite her status as Class 1 beneficiary, if Defendant Del Valle would be charged and convicted in the death of the Insured, she would be barred from receiving the Death Benefit under Pennsylvania’s Slayer Statute. (Id. ¶¶ 14-15); see also 20 Pa. C.S.A. § 8811(a) (“Insurance proceeds payable to the slayer as the beneficiary or assignee of any policy or

certificate of insurance on the life of the decedent . . . shall be paid to the estate of the decedent, unless the policy or certificate designates some person not claiming through the slayer as alternative beneficiary to him.”). As noted by Plaintiff, if Defendant Del Valle were disqualified from receiving the Death Benefit under the Pennsylvania Slayer Statute, A.S. and R.S. (the “Minor Children”) would be entitled to the Death Benefit as Class 2 beneficiaries pursuant to the terms of the TCA. (Id. ¶ 15.) Also as noted by Plaintiff, the Minor Children are in the care of their surviving parent and legal guardian, Defendant Del Valle. (Id. ¶ 16.) Accordingly, in its Interpleader Complaint, Plaintiff identified a potential conflict that may exist

2 if Defendant Del Valle represented the Minor Children’s interests and/or received the Death Benefit on their behalf, in the event she was disqualified from receiving the Death Benefit in her individual capacity. (Id. ¶ 16.) Because of that potential conflict, Plaintiff filed a consent Motion to Appoint Attorney Ad Litem on April 22, 2020. (Doc. No. 6.) The Court granted the

motion and appointed Gail Guida Souders, Esq. as Guardian Ad Litem for the Minor Children in connection with these proceedings. (Doc. No. 7.) Plaintiff claims no interest in the Death Benefit, and asserts that it is ready and willing to pay the Death Benefit to the person/persons entitled to it, but under the circumstances, it cannot make a determination as to the proper recipient of the Death Benefit without exposing itself to potential multiple liability as a result of the potentially competing claims available to Defendants. (Doc. No. 1 ¶ 18.) Accordingly, Plaintiff’s Interpleader Complaint seeks to deposit the Death Benefit, together with accrued claim interest, if any, into the Court’s registry, and be discharged from all liability to Defendants. (Id. ¶ 20.) On June 5, 2020, Defendant Del Valle filed an Answer to the Interpleader Complaint. (Doc. No. 10.) The Court held a case

management conference with the parties on June 15, 2020. (Doc. No. 13.) Accordingly, the Joint Motion for Interpleader Relief is now ripe for disposition. II. DISCUSSION Interpleader is an equitable remedy through which a person holding property, or a stakeholder, can “join in a single suit two or more persons asserting claims to that property.” See Metro. Life Ins. Co. v. Price, 501 F.3d 271, 275 (3d Cir. 2007) (quoting NYLife Distribs., Inc. v. Adherence Grp., Inc., 72 F.3d 371, 372 n.1 (3d Cir. 1995)). When a stakeholder admits liability to one of the claimants but seeks to avoid the possibility of multiple liability,

3 interpleader permits it “to file suit, deposit the property with the [C]ourt, and withdraw from the proceedings.” See Prudential Ins. Co. of Am. v. Hovis, 553 F.3d 258, 262 (3d Cir. 2009) (quoting Price, 501 F.3d at 275). As a result, “[t]he competing claimants are left to litigate between themselves,” and the stakeholder is discharged from any further liability. See id.

(quoting Price, 501 F.3d at 275). There are two options for a party seeking interpleader relief: (1) the federal interpleader statute, 28 U.S.C. § 1335, and (2) Federal Rule of Civil Procedure 22. District courts have subject matter jurisdiction under 28 U.S.C. § 1335 if there is minimal diversity between two or more adverse claimants and if the amount in controversy is $500.00 or more. See 28 U.S.C. § 1335(a). However, by contrast, “rule interpleader is no more than a procedural device; the plaintiff must plead and prove an independent basis for subject matter jurisdiction.” See Price, 501 F.3d at 275. Plaintiff does not rely on the interpleader statute, given that the potential adverse claimants seeking the Death Benefit are all citizens of Pennsylvania. Instead, Plaintiff relies on rule interpleader, and pleads diversity jurisdiction under 28 U.S.C.§ 1332 because

Plaintiff is a citizen of New York and Defendants are citizens of Pennsylvania. (Doc. No. 1 ¶ 5.) Rule 22 of the Federal Rules of Civil Procedure

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