Unum Life Insurance Company of America v. Smith

CourtDistrict Court, D. Idaho
DecidedApril 16, 2025
Docket1:23-cv-00426
StatusUnknown

This text of Unum Life Insurance Company of America v. Smith (Unum Life Insurance Company of America v. Smith) is published on Counsel Stack Legal Research, covering District Court, D. Idaho 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. Smith, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

UNUM LIFE INSURANCE COMPANY OF AMERICA, Case No. 1:23-cv-00426-DCN

Plaintiff, MEMORANDUM DECISION AND ORDER v.

STEVEN J. SMITH, an individual, and KRISTI HOLLEY, in her capacity as Personal Representative of the Estate of Dawn Marie Steinmetz,

Defendants.

I. INTRODUCTION Before the Court are Defendant Steven J. Smith’s Motion for Summary Judgment (Dkt. 46) and Motion for Settlement (Dkt. 45). Having reviewed the record and the briefs, the Court finds that the facts and legal arguments are adequately presented, and the decisional process would not be significantly aided by oral argument. Accordingly, the Court will rule on the Motions without oral argument. Dist. Idaho Loc. Civ. R. 7.1(d)(1)(B). Upon review, and for the reasons set forth below, the Court DENIES Smith’s Motion for Summary Judgment and GRANTS in part and DENIES in part Smith’s Motion for Settlement. II. BACKGROUND A. Factual Background This action was initiated by Unum Life Insurance Company of America (“Unum”) pursuant to Federal Rule of Civil Procedure 22 and 28 U.S.C. §§ 1335, 1397, and 2361. Unum requested that the Court determine the proper beneficiary of a life insurance policy. Unum then sought interpleader relief, asking the court to accept the Plan Benefits as a

deposit, minus its attorney fees. The Court granted the interpleader relief. Dkt. 42. During her life, Dawn Marie Steinmetz was an employee of Ensign Services, Inc. (“Ensign”), and a participant in a life and accidental death and dismemberment plan sponsored by Ensign and administered by Unum (the “Plan”). The Plan guarantees $25,000 in basic life coverage, $200,000 in supplemental life coverage, and $25,000 in basic

accidental death and dismemberment coverage (the “Plan Benefits”). Steinmetz died on July 28, 2022, making the Plan Benefits payable to the proper beneficiary. Kristi Holley—on behalf of the Estate of Steinmetz—and Smith have asserted competing claims to the Plan Benefits. At the time of Steinmetz’s death, Smith was named as the primary beneficiary of the Plan. However, Smith was arrested on July 28, 2022—

the date of Steinmetz’s death—and was charged with murder for allegedly fatally shooting Steinmetz in the chest. Smith ultimately negotiated a plea agreement, pled guilty to involuntary manslaughter, and was sentenced on November 22, 2024. Dkt. 62, at 2. B. Procedural Background On May 8, 2024, Holley filed a Motion for Summary Judgment requesting the

insurance proceeds be paid to the estate. Dkt. 24, at 3. The Court denied that Motion because, at that point, whether Smith intentionally killed Steinmetz was a disputed material fact. Dkt. 42, at 16. On May 28, 2024, Smith filed a Motion for Settlement. Dkt. 29. In that motion, Smith, among other things, proposed that the policy be split equally between the estate and himself. See, Dkt. 29-1. The Court denied that “motion” because settlement negotiations are between parties without the Court’s involvement. Dkt.42.

On September 5, 2024, Smith filed a Motion for Proposed Settlement Offer. Dkt. 45. In his Motion, Smith proposes that the Court award him $110,000.00 and award the Estate of Steinmetz $130,000.00. Id. at 2. Holley filed a response on January 2, 2025, in which she asserts that the estate would be “willing to participate in a judicial settlement conference” pursuant to Local Civil Rule 16.4(b)(2). Dkt. 61, at 2.

Also on September 5, 2024, Smith filed a Motion for Summary Judgement. Dkt. 46. In this Motion, Smith’s primary claim is that his wife’s killing was accidental, and therefore, he is still entitled to the benefits of the policy. Dkt. 46-2, at 8. Holley filed a response on January 2, 2025, opposing Smith’s Motion for Summary Judgement. Dkt. 62. Holley argues the killing was probably intentional and cites Smith’s

expert’s Firearm Analysis and other undisputed evidence in support of the killing being intentional. Id. Ultimately, Holley requests summary judgment be granted in favor of the estate. Dkt. 62, at 4. III. LEGAL STANDARDS A. Summary Judgment

Summary judgment is proper “if the movant shows that 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). The Court’s role at summary judgment is not “to weigh the evidence and determine the truth of the matter but to determine whether there is a genuine issue for trial.” Zetwick v. Cnty. of Yolo, 850 F.3d 436, 441 (9th Cir. 2017) (cleaned up). In considering a motion for summary judgment, the Court must “view[] the facts in the non-moving party’s favor.” Id. To defeat a motion for summary judgment, the non-moving party need only

present evidence upon which “a reasonable juror drawing all inferences in favor of the respondent could return a verdict in [his or her] favor.” Id. (cleaned up). On the other hand, to succeed on a motion for summary judgment, the moving party must either (1) “produce evidence negating an essential element of the nonmoving party’s claim or defense,” or (2) “show that the nonmoving party does not have enough evidence of an essential element to

carry its ultimate burden at trial.” Nissan Fire & Marine Ins. Co., Ltd. v. Fritz Companies, Inc., 210 F.3d 1099, 1102 (9th Cir. 2000). B. Maine Probate Law and Involuntary Manslaughter The Plan’s Summary of Benefits identifies Maine as the governing jurisdiction under its choice-of-law provision.1 Dkt. 1-1, at 3, 66. Under Maine’s Probate Code, one

“who feloniously and intentionally kills the decedent forfeits all benefits under this Article with respect to the decedent’s estate . . . .” ME. REV. STAT. ANN. tit. 18-C, § 2-802(2) (2019). To determine whether there has been a felonious and intentional killing, there must be a judgment of conviction establishing such, or “[i]n absence of a conviction, the court,

1 Where, as here, an action is brought under 28 U.S.C. § 1335, the federal district court should “apply the substantive law that a court of the forum state would apply.” Equitable Life Assurance Soc’y of U.S. v. McKay, 837 F.2d 904, 905 (9th Cir. 1988). Idaho has a statute similar to Maine’s, prohibiting a slayer from benefiting from his or her misdeeds. IDAHO CODE § 15-2-803(j)(1). However, “Idaho generally enforces choice-of-law provisions in contracts,” unless doing so would run contrary to a fundamental state policy. Stimpson v. Midland Credit Management, Inc., 347 F. Supp. 3d 538, 546 (D. Idaho 2018), aff’d, 944 F.3d 1190 (9th Cir. 2019). Neither party has raised, nor is the Court aware of any fundamental Idaho policy that would be violated by the Court’s decision to honor the choice-of-law provision here. Accordingly, the Court finds the Maine statute, and not the Idaho statute, to be controlling.

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Unum Life Insurance Company of America v. Smith, Counsel Stack Legal Research, https://law.counselstack.com/opinion/unum-life-insurance-company-of-america-v-smith-idd-2025.