AMERITAS LIFE INSURANCE CORP. v. ZHANG
1:24-cv-07376
| D.N.J. | Apr 30, 2025Background
- Ameritas Life Insurance Corp. brought an interpleader action regarding a $1 million life insurance policy originally held by Feng Guan Lu.
- The Policy initially listed Chu Ming Lu (Chu) as sole beneficiary, then was changed to name Qi Sheng Zhang (Zhang) as beneficiary; this change is contested as possibly fraudulent.
- Upon the insured's death in 2024, competing claims to the policy proceeds were made by Zhang, Chu, and Tony Lu (the insured’s other son, who cited alleged oral promises).
- Ameritas, the insurer, claimed no interest in the proceeds and declined to pay any claimant in light of the disputes, instead seeking court guidance.
- Ameritas sought to deposit the funds in court, be discharged from liability, enjoin further related suits, and recover attorneys’ fees and costs.
- Defendants did not oppose the motion; the court’s determination focused on procedural interpleader issues under 28 U.S.C. § 1335.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject Matter Jurisdiction | $1M policy, minimal diversity, ready to deposit funds | No opposition (diversity and amount not contested) | Jurisdiction granted if proceeds deposited in court |
| Propriety of Interpleader | Multiple adverse claims, risk of multiple liability | No opposition | Interpleader warranted; Ameritas to be discharged |
| Discharge from Liability | Should be released from liability after deposit | No opposition | Ameritas conditionally discharged upon deposit |
| Attorneys’ Fees and Costs | Ameritas requests reimbursement from policy fund | Not at issue (no opposition, but not ripe) | Request denied without prejudice; may renew post-deposit |
Key Cases Cited
- NYLife Distributors, Inc. v. Adherence Grp., Inc., 72 F.3d 371 (3d Cir. 1995) (describes the purpose and mechanism of federal interpleader actions)
- Metro. Life Ins. Co. v. Price, 501 F.3d 271 (3d Cir. 2007) (sets forth the procedures for statutory and rule interpleader; details benefits of consolidating disputes)
- Prudential Ins. Co. of Am. v. Hovis, 553 F.3d 258 (3d Cir. 2009) (identifies two-stage approach in interpleader actions: jurisdiction/discharge and claims resolution)