Unum Life Insurance Company of America v. Knoll

CourtDistrict Court, N.D. Iowa
DecidedDecember 10, 2024
Docket5:24-cv-04045
StatusUnknown

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

Bluebook
Unum Life Insurance Company of America v. Knoll, (N.D. Iowa 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF IOWA WESTERN DIVISION

UNUM LIFE INSURANCE COMPANY OF AMERICA,

Plaintiff, No. C24-4045-LTS-MAR vs. MEMORANDUM FORREST D. KNOLL, individually; OPINION AND ORDER PHILLIP E. KNOLL, as Conservator on behalf of L.M.B., a minor, and PHILLIP E. KNOLL, as Conservator of N.P.K., a minor,

Defendants.

I. INTRODUCTION This interpleader action is before me on an unresisted motion (Doc. 16) by plaintiff Unum Life Insurance Company (Unum) for interpleader relief. Unum requests an order directing deposit of the insurance benefits at issue, plus interest, minus $7,500 in reasonable attorney’s fees and $350 in costs.

II. BACKGROUND On August 15, 2024, Unum filed a complaint (Doc. 1) for interpleader pursuant to Federal Rule of Civil Procedure 22 and 28 U.S.C. §§ 1132(e), 1331, 1335 and 1391. The complaint names as defendants Forrest Knoll, individually, and Phillip Knoll, as Conservator of L.M.B. and N.P.K.,1 to resolve competing claims following the death of Ann Michelle Krummen (the decedent) to $1,061,100 in benefits under group policies

1 L.M.B. and N.P.K. are both minors. Unum issued to participating employees of Tyson Foods, Inc.2 Defendants have each filed an answer (Docs. 9, 13) to the complaint. Both consent to the interpleader relief requested in Unum’s motion. See Doc. 16-2 at 4.

III. ANALYSIS A. Interpleader and Dismissal “Interpleader is a procedural device whereby a party holding money or property concededly belonging to another may join in a single suit two or more parties asserting mutually exclusive claims to the fund. The stakeholder is thereby freed from the threat of multiple liability and/or the vexation of multiple lawsuits.” Gaines v. Sunray Oil Co., 539 F.2d 1136, 1141 (8th Cir. 1976) (citing 3A Moore’s Federal Practice P 22.02(1) (1974)). Unum brings this interpleader action pursuant to 28 U.S.C. § 1335. The federal interpleader statute provides: (a) The district courts shall have original jurisdiction of any civil action of interpleader or in the nature of interpleader filed by any person, firm, or corporation, association, or society having in his or its custody or possession money or property of the value of $500 or more, or having issued a note, bond, certificate, policy of insurance, or other instrument of value or amount of $500 or more, or providing for the delivery or payment or the loan of money or property of such amount or value, or being under any obligation written or unwritten to the amount of $500 or more, if

2 Specifically, Unum has identified the following coverage, which it collectively refers to as the death benefits:

- Base life - $101,000 - Base accidental death & dismemberment (AD&D) - $101,000 - Supplemental life - $301,000 - Supplemental AD&D - $501,000 - Supplemental AD&D seatbelt benefit - $50,100 - Supplemental AD&D childcare default benefit - $2,000 - Supplemental airbag benefit - $5,000 - Doc. 16-1 at 1-2. (1) Two or more adverse claimants, of diverse citizenship as defined in subsection (a) or (d) of section 1332 of this title, are claiming or may claim to be entitled to such money or property, or to any one or more of the benefits arising by virtue of any note, bond, certificate, policy or other instrument, or arising by virtue of any such obligation; and if (2) the plaintiff has deposited such money or property or has paid the amount of or the loan or other value of such instrument or the amount due under such obligation into the registry of the court, there to abide the judgment of the court, or has given bond payable to the clerk of the court in such amount and with such surety as the court or judge may deem proper, conditioned upon the compliance by the plaintiff with the future order or judgment of the court with respect to the subject matter of the controversy.

(b) Such an action may be entertained although the titles or claims of the conflicting claimants do not have a common origin, or are not identical, but are adverse to and independent of one another.

28 U.S.C. § 1335. Jurisdiction is appropriate based on this statute as the amount at stake is over $500 and at least two of the parties are diverse (Doc. 1). Interpleader is also addressed by Federal Rule of Civil Procedure 22: (a) Grounds.

(1) By a Plaintiff. Persons with claims that may expose a plaintiff to double or multiple liability may be joined as defendants and required to interplead. Joinder for interpleader is proper even though:

(A) the claims of the several claimants, or the titles on which their claims depend, lack a common origin or are adverse and independent rather than identical; or (B) the plaintiff denies liability in whole or in part to any or all of the claimants.

(2) By a Defendant. A defendant exposed to similar liability may seek interpleader through a crossclaim or counterclaim.

(b) Relation to Other Rules and Statutes. This rule supplements--and does not limit--the joinder of parties allowed by Rule 20. The remedy this rule provides is in addition to--and does not supersede or limit--the remedy provided by 28 U.S.C. §§ 1335, 1397, and 2361. An action under those statutes must be conducted under these rules.

Fed. R. Civ. P. 22. Interpleader actions typically proceed in two stages. United States v. High Tech. Prod., Inc., 497 F.3d 637, 641 (6th Cir. 2007). During the first stage, the court determines whether the stakeholder has properly invoked interpleader, including whether the court has jurisdiction over the suit, whether the stakeholder is actually threatened with double or multiple liability, and whether any equitable concerns prevent the use of interpleader. During the second stage, the court determines the respective rights of the claimants to the fund or property at stake via normal litigation processes, including pleading, discovery, motions, and trial.

Id. (internal citations omitted) (citing 7 Charles A. Wright, Arthur R. Miller, Mary Kay Kane, Federal Practice and Procedure § 1714 (3d ed. 2001)). When the court decides that interpleader is available, it may issue an order discharging the stakeholder, if the stakeholder is disinterested, enjoining the parties from prosecuting any other proceeding related to the same subject matter, and directing the claimants to interplead; the court also may make any other order that is appropriate and convenient for the resolution of the competing claims.

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Unum Life Insurance Company of America v. Knoll, Counsel Stack Legal Research, https://law.counselstack.com/opinion/unum-life-insurance-company-of-america-v-knoll-iand-2024.