The Prudential Insurance Company of America v. Gledhill

CourtDistrict Court, D. Utah
DecidedOctober 6, 2025
Docket2:25-cv-00200
StatusUnknown

This text of The Prudential Insurance Company of America v. Gledhill (The Prudential Insurance Company of America v. Gledhill) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Prudential Insurance Company of America v. Gledhill, (D. Utah 2025).

Opinion

THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH

THE PRUDENTIAL INSURANCE MEMORANDUM DECISION AND COMPANY OF AMERICA, a domestic ORDER DENYING [18] PLAINTFF’S business corporation, MOTION FOR APPOINTMENT OF GUARDIAN AD LITEM AND DEPOSIT Plaintiff/Interpleader, OF DEATH BENEFITS

v. Case No. 2:25-cv-00200-DBB-DAO

JENNIFER GLEDHILL, an individual; N.J., a District Judge David Barlow minor; Ai.J., a minor; An.J., a minor,

Defendants.

Before the court is Plaintiff Prudential Insurance Company of America’s (“Prudential”) Motion for Appointment of Guardian Ad Litem and Deposit of Death Benefits.1 BACKGROUND Prudential filed an interpleader Complaint on March 14, 2025, in which it alleges the following.2 Prudential is an insurance company that provides Servicemembers Group Life Insurance (SGLI) policies to the Department of Veteran Affairs.3 Matthew Johnson was insured under a Prudential SGLI policy in the amount of $500,000.4 Mr. Johnson’s wife, Jennifer Gledhill, was named as the primary beneficiary of the policy.5 He also had three minor children

1 Mot. for Appointment of Guardian Ad Litem and Deposit of Death Benefits (“Mot.”), ECF No. 18, filed Aug. 8, 2025. 2 Compl., ECF No. 1, filed Mar. 14, 2025. 3 Id. ¶ 8. 4 Id. ¶ 9. 5 Id. ¶ 10. with Ms. Gledhill.6 Mr. Johnson died on September 20, 2024.7 His wife, Ms. Gledhill, was

subsequently charged with his murder and is currently incarcerated at Salt Lake Metropolitan Jail while she awaits the results of her pending criminal action in Utah state court.8 SGLI policies are governed by federal statute.9 The relevant statute prohibits a person convicted of wrongfully killing the insured from receiving any proceeds from the policy.10 If a primary beneficiary is thus disqualified, the proceeds pass as directed by the statute.11 In this case, the $500,000 death benefits would pass to Mr. Johnson’s minor children if Ms. Gledhill were convicted.12 After Prudential filed this action, it served its Complaint on Ms. Gledhill, and her counsel filed an appearance on her behalf.13 The minor defendants have not yet accepted service or appeared.14

STANDARD “Federal courts have jurisdiction to hear two forms of interpleader actions: statutory interpleader and rule interpleader.”15 Subject-matter jurisdiction in a statutory interpleader case arises from 28 U.S.C. § 1335 when (1) “[t]wo or more adverse claimants, of diverse citizenship,” (2) “are claiming or may claim” property or money worth $500 or more, and (3) the plaintiff deposits the disputed funds or a bond with the court.16 Rule interpleader under Rule 22 of the

6 Id. ¶¶ 3–5. 7 Id. ¶ 11. 8 Id. ¶¶ 2, 12. 9 Id. ¶ 14. 10 Id. 11 Id. ¶ 15. 12 Id. ¶ 17. 13 Mot. 2; see also Return of Service for Jennifer Gledhill, ECF No. 14, entered May 5, 2025. 14 See generally docket. 15 Clausen as Tr. of Brett M. Partridge Tr. v. Protective Life Ins. Co., No. 2:22-CV-00757-TC-DAO, 2023 WL 4137370, at *2 (D. Utah June 22, 2023). 16 28 U.S.C.A. § 1335(a). Federal Rules of Civil Procedure provides no special basis for subject-matter jurisdiction and allows “[p]ersons with claims that may expose a plaintiff to double or multiple liability” to be “joined as defendants and required to interplead.”17 “In an action in interpleader, the court must . . . determine whether a single, identifiable stake is present” and “whether there are two or more adverse claims to that stake, focusing on the substance of the legal claims asserted.”18 DISCUSSION In this case, statutory interpleader does not apply because none of the adverse claimants are diverse.19 However, there is jurisdiction for rule interpleader because the claim arises under a law of the United States with regard to the governing SGLI statute,20 the amount in controversy exceeds $75,000, and Prudential and the Defendants are diverse.21

In its Complaint, Prudential asserts that interpleader is appropriate in this case because it cannot determine the proper party to receive the death benefit without “exposing itself to double or multiple liability on account of the potential competing claims made by or available to Defendants.”22 It then asks the court in its Motion to appoint a guardian ad litem for the minor defendants “for the purposes of accepting service of the Interpleader Complaint” and to represent their interests.23 It also requests that the death benefit be deposited with the court and that “the guardian ad litem be compensated out of the deposited funds.”24

17 Fed. R. Civ. P. 22(a)(1). 18 In re Millennium Multiple Emp. Welfare Ben. Plan, 772 F.3d 634, 642 (10th Cir. 2014). 19 28 U.S.C.A. § 1335(a); Compl. ¶¶ 2–5. 20 28 U.S.C.A. § 1331; Compl. ¶ 6. 21 28 U.S.C.A. § 1332(a); Compl. ¶¶ 1–5, 9. 22 Compl. ¶ 18. 23 Mot. 2. 24 Id. at 5. Interpleader actions generally proceed in two stages.25 The court must first determine “whether the plaintiff ‘has properly invoked interpleader, including whether the court has jurisdiction over the suit, whether the plaintiff is actually threatened with double or multiple liability, and whether any equitable concerns prevent the use of interpleader.’”26 Assuming interpleader is proper, the court may permit the plaintiff to pay the disputed funds into the registry of the court and then discharge the plaintiff.27 Once the plaintiff is discharged, the second stage involves determining “the relative rights of the parties to the funds at issue.”28 Here, interpleader is not appropriate at this time. Interpleader is often proper in circumstances involving death benefits and possible disqualifications under slayer statutes.29 However, certain aspects of this case weigh against permitting interpleader as the case currently

stands. First, there is no immediate threat of multiple liability. Courts usually determine whether multiple adverse claims to an interpled stake exist by “focusing on the substance of the legal claims asserted.”30 Prudential does not allege in its Complaint that any defendant has even requested the benefit, much less asserted a legal claim.31 Any threat of double liability is purely hypothetical at this point and may never materialize if Ms. Gledhill is convicted before any party asserts a claim to the benefit.

25 United States v. High Tech. Prods., Inc., 497 F.3d 637, 641 (6th Cir. 2007). 26 Metro. Life Ins. Co. v. Asbell, No. 21-CV-00332-RAW, 2023 WL 1967299, at *3 (E.D. Okla. Feb. 13, 2023) (quoting High Tech Prods, 497 F.3d at 641). 27 Id. 28 Id. 29 See Aetna U.S. Healthcare v. Higgs, 962 F. Supp. 1412, 1414 (D. Kan. 1997) (explaining that “the Tenth Circuit ha[s] demonstrated a clear preference for the interpleader process in cases” involving death benefits and slayer statutes); Glass v. United States, 506 F.2d 379, 383 (10th Cir. 1974) (noting that “interpleader action . . . is specifically designed” for cases like those involving a disputed benefit and a slayer statute). 30 In re Millennium Multiple Emp. Welfare Ben. Plan, 772 F.3d 634, 642 (10th Cir. 2014). 31 See Compl. Second, no legal analysis is necessary or possible at this juncture.

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Related

United States v. High Technology Products, Inc.
497 F.3d 637 (Sixth Circuit, 2007)
Aetna U.S. Healthcare v. Higgs
962 F. Supp. 1412 (D. Kansas, 1997)
Glass v. United States
506 F.2d 379 (Tenth Circuit, 1974)

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